The European Union has continued to refine its approach to sanctions compliance by publishing new guidance on the critical issues of “ownership” and “control” through its Sanctions Helpdesk platform. The guidance—released in late August 2025—offers much-needed clarity on how companies operating within the Union should identify, evaluate, and manage the risks posed by indirect links to sanctioned parties. In particular, the document provides detailed direction...

Webinar: DOJ Pushes Aggressive Trade Enforcement Strategy October 21, 2025, 12 Noon Sign-Up HERE The Trump Administration has warned that DOJ and regulatory agencies (OFAC, BIS and DDTC) intend to seek stiff punishment for violations of tariffs, sanctions and export controls. DOJ’s new initiative has been unveiled in two significant enforcement actions — Cadence Design Systems and Unicat Catalyst — where DOJ organized a comprehensive...

The Trump Justice Department has fully embraced the False Claims Act, stretching its use to include trade enforcement.  DOJ recognizes the power of the FCA, the issues at stake, and the ability to extract large settlements.  DOJ has used the FCA to capture companies that evade customs duties.  DOJ’s recent actions are a reminder for import companies to carefully scrutinize valuation and customs duties to...

In a final rule scheduled for publication in the Federal Register on September 2, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) formally implemented sweeping changes to the Export Administration Regulations (“EAR”) as they pertain to the Syrian Arab Republic. The action follows Executive Order 14312, Providing for the Revocation of Syria Sanctions, issued on June 30, 2025, in which the...

On September 3, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $1,610,775 settlement with Fracht FWO Inc. (“Fracht”), an international freight forwarder headquartered in Houston, Texas, in connection with apparent violations of multiple U.S. sanctions programs, including those targeting Venezuela and Iran. The matter arose from a May 2022 transaction in which Fracht, responding to urgent customer demands,...

What do you do when the headlines shift faster than your risk matrix can keep up? In this episode, Michael Volkov dives into the challenge of adapting compliance programs in the face of volatile and fast-changing global risks—from tariffs and trade controls to supply chain disruptions and third-party exposures. While the pressure to react is constant, the real key is staying anchored in your company’s...

The Trump Administration’s handling of antitrust enforcement issues is generally viewed as a wild-card — meaning there are issues of concern or focus that may not fit the “traditional” antitrust enforcement model. Depending on the issue and the players, DOJ’s antitrust interest may surprise various practitioners and commentators. Trump’s nomination of Gail Slater as DOJ’s Assistant Attorney General for the Antitrust Division was universally praised...

With the beginning of the aggressive trade enforcement era, companies need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important. As we embark on a new criminal enforcement era surrounding sanctions violations, companies have to address this issue and do it correctly. In this episode, Michael Volkov takes a comprehensive look at third-party risks from the distribution...

With all of the hoopla and hysteria focused on AI and information systems, Threat.Digital, a long-time affiliate of The Volkov Law Group, Chris Focacci, CEO of Threat Digital, is a technology leader.  Chris has the ability to explain practical application of AI technology, due diligence and information systems.  He is a terrific resource and I urge all interested parties to reach out and speak with...