Featured Articles:

Soothing the AI-Risk Hysteria: A Focused Approach to AI Risks (Part I of II)

From my perspective, hopefully a reasonable one, there is a little too much AI-Risk Hype.  Not to belittle the experts or ignore potential risk concerns but this is getting a little carried away.  The compliance industry appears to be taken over by AI-this and AI-that.  Third party risk bleeds into major AI risks, corporate governance needs to incorporate AI risks, and policies and procedures have...

Here They Come: DOJ Brings False Claims Act to Tariffs and Duty Enforcement (Part II of II)

Here They Come: DOJ Brings False Claims Act to Tariffs and Duty Enforcement (Part II of II)

The Justice Department knows how to use the False Claims Act — it is the primary tool against fraudsters in the healthcare industry, and going back even further, it was used against the defense industry in the 1980s and 1990s.  DOJ has turned the tool towards another angle and this portends a significant trend.  DOJ is opening up a new front in the trade enforcement...

Trade Enforcement: A Look Back (Part I of II)

Trade Enforcement: A Look Back (Part I of II)

Typically, I enjoy the New Year (notwithstanding Larry David’s rule of no New Year wishes past 15 days of the New Year).  It is important to look back, assess and identify trends; after all, what better marker than annual reviews. The most significant compliance and enforcement issue remains trade enforcement — sanctions and export controls.  In the second posting, I want to focus on the...

BIS Imposes $1.5 Million Penalty on Exyte for Unlicensed In-Country Transfers to SMIC

BIS Imposes $1.5 Million Penalty on Exyte for Unlicensed In-Country Transfers to SMIC

On January 7, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an Order resolving an administrative enforcement action against Exyte Management GmbH, a Germany-based company headquartered in Stuttgart, in connection with alleged violations of the Export Administration Regulations (“EAR”). The action arose from conduct occurring between March 2021 and March 2022 and involved in-country transfers of items subject to the...

Corporate Compliance and the Steady-State: Focus on Ethics and Values

Corporate Compliance and the Steady-State: Focus on Ethics and Values

Welcome to 2026, a 10/1 year in numerology (if you are into it).  Wherever you might be on the political spectrum, we can all agree that there is a lot happening, and there has been some significant changes.  While I occasionally hear about the impact of our social climate on corporate ethics and compliance, let me offer a positive perspective that confirms the continuing —...