As we continue through the maze of Executive Orders and new Guidance, which is expected in 180 days, the questions surrounding FCPA enforcement are swirling. In some respects, we have had a preview. It is hard to know what will happen beyond some basic points. Let’s start with last week’s memo issued by Attorney General Bondi, which was entitled — Total Elimination of Cartels and...
What an amazing turn of events? — Who would have predicted that the Trump Administration would take such a bold action in the name of advancing “American Competitiveness.” I admit I did not see this coming — the Trump Administration during the first term had an aggressive record of FCPA enforcement. We all expected that to continue. Boardrooms, C-Suites and Legal/Compliance professionals are stunned. How...
In an unprecedented action, the Trump Administration pushed the button and ended FCPA enforcement, at least for 180 days, until new guidance is issued by the Department of Justice. The White House’s announcement seemed to take everyone by “surprise” but in the end was “expected” in light of recent announcements coming from Attorney General Bondi. The President’s Executive Order In an Executive Order that appeared...
In an unprecedented and surprising set of actions, the new Attorney General Bondi issued eleven new, internal directives for the Department of Justice. The new Directives are available HERE. Immediately after her confirmation and swearing in, AG Bondi issued 14 separate directives that hit the Justice Department with significant changes in policy and priorities. Eliminating Internal Discriminatory Practices: Following President Trump’s Executive Order, Ending Illegal...
How do sanctioned Russian oligarchs continue to move their wealth despite international restrictions? The answer lies in real estate, shell companies, and complicit gatekeepers. In this episode of Corruption, Crime, and Compliance, Michael Volkov dives into one of the latest OFAC enforcement actions against Family International and its owner, Roman Sinyavsky, for facilitating sanctions evasion on behalf of Russian oligarchs. Through complex real estate transactions,...
Family International, a Florida real estate company, and its U.S. owner, Roman Sinyavsky, settled with OFAC for $1.07 million for 73 violations of the Russia Sanctions program. In a separate criminal case, Roman Sinyavsky pleaded guilty to circumventing U.S. sanctions and money laundering. Between 2018 and 2023, and 2023, Family International and Sinyavsky transferred nominal ownership of three luxury condominiums owned by two sanctioned Russian...
February 25, 2025 12 Noon EST SIGN UP HERE Companies face a fast-changing enforcement and compliance environment. The Trump Administration is setting new priorities and focusing on immigration, trade compliance, including sanctions and export controls. In the midst of this rapidly-evolving environment, companies have to prioritize compliance elements and mitigation strategies. The Justice Department with its regulatory partners are continuing to focus on anti-corruption, sanctions,...
In one of the first enforcement actions of 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order against Haas Automation, Inc., a leading manufacturer of computer numerical control (“CNC”) machines, for dozens of violations of the Export Administration Regulations (“EAR”). The enforcement action stems from allegations that Haas facilitated the unauthorized export, reexport, or transfer of U.S.-origin machine...
The 1990s saw the explosion of the internet, transforming the global economy and social development in ways we could have never imagined. But will AI truly have the same impact? While its potential is undeniable, the road ahead is full of risks, challenges, and ethical concerns. Will AI drive efficiency and innovation, or will it create new vulnerabilities that companies must scramble to control? In...
When evaluating AI risks, legal, ethics and compliance professionals need to divide the question into two — first, what are risks from legal, ethics and compliance internal use of AI? and second, what are business risks from employing AI capabilities in specific functions and use cases? Sometimes ethics and compliance professionals are surprised to learn that certain functions — finance, security, HR or others —...
