In a final rule scheduled for publication in the Federal Register on September 2, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) formally implemented sweeping changes to the Export Administration Regulations (“EAR”) as they pertain to the Syrian Arab Republic. The action follows Executive Order 14312, Providing for the Revocation of Syria Sanctions, issued on June 30, 2025, in which the...

On September 3, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $1,610,775 settlement with Fracht FWO Inc. (“Fracht”), an international freight forwarder headquartered in Houston, Texas, in connection with apparent violations of multiple U.S. sanctions programs, including those targeting Venezuela and Iran. The matter arose from a May 2022 transaction in which Fracht, responding to urgent customer demands,...

What do you do when the headlines shift faster than your risk matrix can keep up? In this episode, Michael Volkov dives into the challenge of adapting compliance programs in the face of volatile and fast-changing global risks—from tariffs and trade controls to supply chain disruptions and third-party exposures. While the pressure to react is constant, the real key is staying anchored in your company’s...

With the beginning of the aggressive trade enforcement era, companies need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important. As we embark on a new criminal enforcement era surrounding sanctions violations, companies have to address this issue and do it correctly. In this episode, Michael Volkov takes a comprehensive look at third-party risks from the distribution...

With all of the hoopla and hysteria focused on AI and information systems, Threat.Digital, a long-time affiliate of The Volkov Law Group, Chris Focacci, CEO of Threat Digital, is a technology leader.  Chris has the ability to explain practical application of AI technology, due diligence and information systems.  He is a terrific resource and I urge all interested parties to reach out and speak with...

Is the DOJ really changing its playbook on FCPA enforcement, or is it business as usual under a new administration? In this episode, Michael digs into two headline developments that say a lot about where things are headed – the first FCPA declination under the Trump Administration and the first indictment. Both shed light on how DOJ is applying its policies in practice, what companies...

Given the real and significant potential benefits of AI, companies have to be careful in the rush to implement AI technology.  Starting with a clear use case, companies have to weigh the potential benefits of AI technology and identify the legal and compliance risks.  An AI compliance program is a critical element of a corporate governance structure.  Building on this specific policy, companies need to...

The new world of AI presents significant benefits and risks that need to be addressed in an overall governance framework.  Luckily, the principles to apply here will surprise no one — governance, compliance, legal and risk professionals will quickly adapt well-known principles to the new frontier of AI. Starting at the Board level, AI oversight responsibility should be assigned a dedicated board committee, such as...