Corruption, Crime & Compliance

Featured Articles:

7 May, 2025

Voluntary Self-Disclosure Shields Universities Space Research Association from Prosecution by DOJ

On April 30, 2025, the U.S. Department of Justice’s National Security Division (“NSD”) issued a formal declination of prosecution to the Universities Space Research Association (“USRA”) following the organization’s timely and fulsome voluntary self-disclosure of export control violations perpetrated by a former employee. The declination, conveyed through a detailed letter signed by Principal Deputy Assistant Attorney General David Newman, marks one of the clearest applications...

General

5 May, 2025

LRN Issues New Report Highlighting High-Performing Compliance Programs

LRN’s Program Effectiveness Report is an important annual event. LRN consistently provides important trend, benchmarking and program measurements. As an important leader in this area, LRN never pulls any punches. This year’s report is nothing different. In reporting on a survey of 1500 global ethics and compliance professionals, LRN reports on important trends and measurements. This year’s key findings: High-impact programs are more adept at...

Podcasts

5 May, 2025

Episode 367 — Global Anti-Corruption Round Up

The Justice Department’s six-month pause on FCPA enforcement has left a gap in the global anti-corruption fight. The Justice Department played a critical role in coordinating international efforts and enforcement. In the face of these developments, foreign prosecutors and even the State of California have publicized their intention to increase anti-corruption enforcement. In this Episode, Michael Volkov reviews global anti-corruption initiatives and provides updates on...

General

2 May, 2025

Reviewing the CPB Enforcement Process Under 19 U.S.C. § 1592 (Part II of II)

CPB’s administrative enforcement program is robust and increasing, especially with the importance of trade and tariff enforcement. There are a lot of “ins and outs” (Big Lewbowski Here) to the administrative process which can make it appear overly complex. Case Initiation: CBP initiates investigations from a variety of sources including routine audits, cargo examinations, e-allegations, and referrals. The import process, for obvious reasons, includes a...

General

29 Apr, 2025

Stepping Into the Enforcement Spotlight — Customs and Border Patrol and Import Enforcement (Part I of II)

The Trump Administration is committed to a re-defined objective of fair trade. This will have a significant impact on all businesses, across all operational functions. This is not surprising — for years, the United States has pushed global trade as an objective unto itself. The Trump Administration is raising important questions concerning the benefits to U.S. consumers and workers. As part of this new international...

General

29 Apr, 2025

Global Anti-Corruption Efforts and DOJ’s FCPA Pause

The Justice Department’s six-month pause on FCPA enforcement has left a gap in the global anti-corruption fight. The Justice Department played a critical role in coordinating international efforts and enforcement. in the face of these developments, foreign prosecutors and even the State of California have publicized their intention to increase anti-corruption enforcement. UK-France-Switzerland Taskforce On March 20, 2025, the United Kingdom, France and Switzerland announced...

Podcasts

27 Apr, 2025

Episode 366: DOJ Issues Data Security Program Requirements

Could your routine data transfers now violate federal law? The DOJ’s new Data Security Program (DSP) targets the flow of U.S. sensitive personal and government data to foreign adversaries — and the clock is ticking. In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down the Justice Department’s sweeping new Data Security Program, enacted under Executive Order 14117 and finalized in January 2025....

General

24 Apr, 2025

DSP Compliance: DOJ Sets July 8, 2025 Deadline (Part III of III)

As if legal and compliance professionals had enough responsibilities on their plates, DOJ dropped another shoe (to join the tariffs, sanctions and export controls, and immigration issues) and upped the stakes for ethics and compliance programs. DOJ dropped a comprehensive set of new regulations governing data security and gave companies a 90-day head start — once we get to July 8, 2025, DOJ warned that...

General

22 Apr, 2025

Practical Issues and the New DSP (Part II of III)

Like any new regulatory and enforcement scheme, companies face a number of new risks that require understanding. The DSP framework is new, comprehensive and raises significant risks and requires careful design and implementation of effective compliance strategies. Companies will face different risk levels based on their handling of data, specific market practices and security measures. In this post, I will explore some of the interesting...

Events

20 Apr, 2025

Webinar: Navigating Current Trade Compliance Trends

May 20, 2025 12 Noon EST SIGN UP HERE Enforcement risks and compliance are evolving. The Justice Department, DHS-Customs and Border Patrol, the Bureau of Industry and Security, and OFAC are focusing on a range of issues: tariff compliance, imports, sanctions and export controls, with a new emphasis on aggressive regulatory fines and criminal prosecutions. Companies face a fresh set of tariff and import risks,...