Have you heard about the Goldman Sachs banker who bribed his way to a conviction? A federal jury in Brooklyn last week convicted Asante Berko, a former Goldman Sachs executive, on FCPA conspiracy, a substantive FCPA violation, and money laundering conspiracy. Berko managed a deal between a Turkish energy company and the government of Ghana to build a new power plant in Ghana. To win...
The Treasury Department rolled out a significant escalation of its Iran sanctions program on August 24, and this one is worth immediate attention from any organization with even indirect exposure to Iran-related activity, because it combines two things that don’t usually arrive together: a large batch of new designations and a suspension of general licenses that companies may have been relying on for years to...
BIS just settled with Container Manufacturing, an Ohio-based maker of tops for aluminum beverage cans, for $1 million over ten violations of U.S. export controls tied to Russia. On the surface, this looks like a modest regional manufacturer case involving unglamorous industrial spare parts. Underneath, it’s one of the clearest illustrations I’ve seen this year of a principle every compliance officer needs to internalize: a...
If you think your company can smuggle and fly under the radar screen, think again. When your company touches imports, customs, or tariffs, you need to know this. The Justice Department stood up a dedicated trade fraud task force in August of last year. Its first settlement came three months later. This past May, it delivered the largest customs-related False Claims Act recovery ever: $550...
The Commerce Department’s Bureau of Industry and Security announced a settlement with Plexon Inc., a Dallas-based neuroscience company, over eight unlicensed exports of brain-computer interface equipment to a Chinese research institute with direct ties to the People’s Liberation Army. This case deserves attention well beyond the neuroscience and export control communities, because it illustrates exactly how emerging technology controls are catching companies that may not...
L3Harris Technologies parted ways with its chairman and CEO, Christopher Kubasik, after an internal investigation determined he had violated the company’s code of conduct. The company hasn’t detailed the specific conduct at issue, and it went out of its way to state that the departure had nothing to do with financial reporting or operational performance. The market reacted anyway: L3Harris shares dropped nearly 5 percent...
In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down the State Department’s $36 million settlement with BAE Systems, Inc. over more than 100 alleged violations of the International Traffic in Arms Regulations and Arms Export Control Act spanning 2019 through March 2025, including unlicensed technical data exports to China, Canada, the U.K., and Germany, unauthorized defense services in Italy, France, and Indonesia,...
Corruption, Crime & Compliance has grown into one of the most widely read independent platforms in the FCPA, anti-corruption, and compliance space — reaching Chief Compliance Officers, in-house counsel, compliance directors, attorneys, and risk professionals across North America and Europe. We’re now opening a limited number of sponsorship partnerships for companies that want to build visibility and credibility with this audience. Why Partner With Us...
I’m making available a full AI Acceptable Use Policy template, and I wanted to put this out into the world alongside Collin McKee at Endeavors AI, because this template grew directly out of a conversation the two of us had recently on my podcast, Corruption, Crime and Compliance. If you haven’t seen that episode yet, you can watch it here: Corruption, Crime and Compliance with...
Part one of this series laid out why forced labor risk has moved from the sustainability report to the balance sheet: tariffs tied directly to a country’s forced labor record, an import presumption in the United States that can freeze finished goods over a single sub-tier component, and a European regulation that can pull products off shelves entirely. Part two addresses the harder question: what...
