The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) recently imposed a $1 million civil penalty against Teledyne FLIR, a U.S. manufacturer of thermal imaging cameras, for multiple violations of the Export Administration Regulations (EAR) involving exports to China and Hong Kong. The enforcement action highlights a recurring compliance challenge for multinational exporters: the complex application of the EAR’s de minimis rules, as...

Recent enforcement actions by the SEC have reinforced a message that boards and senior leadership have heard before—but too often underestimate in practice: financial reporting risk is a governance risk. When internal controls fail, disclosure judgments are compromised, or performance pressures override discipline, regulators do not view the breakdown as a technical accounting issue. They view it as an oversight failure. The lessons from recent...

In late 2025, the Securities and Exchange Commission (SEC) charged Archer-Daniels-Midland Company (ADM) and three of its former executives with accounting and disclosure fraud, in what has become one of the most significant financial reporting enforcement actions of 2026. The case underscores a fundamental compliance truth: strong internal controls and transparent disclosures are not optional — they are core risk controls that protect investors, markets,...

A real estate executive reached a $3.77 million settlement with the Office of Foreign Assets Control after OFAC accused them of violating U.S. sanctions against Syria. The person — who committed the alleged violations years before the U.S. repealed a host of Syria restrictions in 2025 — provided “managerial services” in their position as a senior official and board member of four Syrian real estate...

The Treasury Department’s Office of Foreign Assets Control (OFAC) has delivered a pointed reminder that sanctions risk is not confined to banks, multinational manufacturers, or energy traders. It extends to schools — even elite athletic boarding schools operating primarily within the United States. In a recent enforcement action, OFAC imposed a civil penalty against IMG Academy, a Florida-based athletic preparatory boarding school, after the school...

For boards and audit committees, culture should be viewed not as an abstract value but as a core internal control—often the most effective one. Traditional controls are necessary but limited. Policies cannot anticipate every scenario. Monitoring systems detect only what they are designed to see. Audits are retrospective. Culture, by contrast, governs behavior when controls are weakest: in gray areas, under pressure, and in decentralized...

Ethics and integrity are often framed as compliance values—important, necessary, but ultimately subordinate to financial performance. That framing misunderstands the role culture plays in sustainable value creation. A strong culture of ethics and integrity is not a cost center or a regulatory hedge; it is a strategic asset that directly influences long-term financial performance, risk stability, and organizational resilience. Organizations with well-developed ethical cultures benefit...