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 The person — who committed the alleged violations years before the U.S. repealed a host of Syria restrictions in 2025 — provided “managerial services” in their position as a senior official and board member of four Syrian real estate...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...

The Commerce Department’s Bureau of Industry and Security (BIS) has sent an unmistakable message to the semiconductor industry: creative interpretations of the Export Administration Regulations (EAR) will not shield companies from significant enforcement risk. BIS imposed a $252 million penalty against Applied Materials — the second-largest fine in the agency’s history — for illegally exporting semiconductor manufacturing equipment to China’s Semiconductor Manufacturing International Corp. (SMIC),...

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...

Tuesday, March 17, 2026 1 pm EST Sign-Up HERE In a fast-chaning risk environment, organizations face serious challenges in adjusting thier compliance program to effectively mitigate new and changing risks. One area of continuing — and even increasing — concern has been conflicts of interest. Ethics and compliance professionals have seen an increase in troublesome conflict of interest issues — from improper subordinate relationships to...

Episode 395 of Corruption, Crime and Compliance features an in-depth conversation with Bob Lemmond, the new CEO of LRN, on the evolving role of ethics and compliance in today’s risk environment. In this episode, Bob discusses how organizations can move beyond “check-the-box” compliance to embed a culture of integrity that drives performance, mitigates misconduct risk, and strengthens stakeholder trust. He shares his perspective on the growing complexity...

FCPA enforcement in 2025 was defined by what did not happen as much as what did. Compared to prior years, the number of publicly announced cases declined sharply, corporate resolutions were fewer, and the overall enforcement posture appeared more restrained. This slowdown, however, reflects a policy recalibration—not a dismantling—of the FCPA enforcement regime. Early in the year, DOJ paused FCPA enforcement activity while it reviewed...