The Justice Department has returned to the FCPA enforcement arena — in a significant development, DOJ announced the resumption of FCPA enforcement, with a new set of enforcement guidance principles.  The new guidance is an important statement governing FCPA investigations and prosecutions. The impact of this new approach will be significant — the precise scope of this renewed focus will depend on certain legal factors,...

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...

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...

How prepared is your organization to handle the evolving landscape of sanctions compliance? In this episode of Corruption, Crime and Compliance, Michael Volkov dives into critical sanctions compliance cases and their implications for global companies. He discusses four significant cases that underscore the necessity of robust compliance programs, particularly in light of increased DOJ enforcement actions. Through these examples, he breaks down the consequences of...

This week we are pleased to bring you one of our most popular episodes of 2024. Please enjoy, and we will be back next week with more insights from the Corruption, Crime, and Compliance podcast. Have you heard of the recent controversies around Boeing 737 MAX and its safety? Have you wondered what is being done about the concerns around it? In this episode of...

We live in a topsy-turvy world.  This is an exaggeration but sets up my points in this blog post. We are now seeing the shuffling of corporate risks and every board, C-Suite and legal, compliance and risk management team has to take a hard look at your company’s risks and reassess and re-rank them. Initial Review Some basic business and technology risks will stay the...