I have written extensively on the importance of trade compliance.  The risk landscape has changed rapidly with the Russia-Ukraine war, the Trump Administration’s focus on tariffs, economic nationalism, and sanctions and export control enforcement.  Along with these significant trends, companies have increased focus on supply chain risks and management. A new report from the World Economic Forum (WEF) and PWC, Trade Compliance for Leadership, presents...

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...

The Unicat settlement provides some important insights into the Trump Administration’s direction on trade enforcement.  It underscores the importance of voluntary disclosure, cooperation and remediation, the tri-part foundation of seeking a favorable enforcement resolution.  Also, it emphasizes the importance of securing disclosure credit with the Justice Department since Unicat’s parent received a declination because of its early disclosure and complete cooperation. In stark contrast, the...

Never underestimate the creativity and ability of federal prosecutors to apply federal criminal laws to address “new” crimes or new enforcement programs.  Corporate leaders and compliance officials are making a serious mistake when they confuse a “pause” in FCPA enforcement to mean a reduction in federal criminal prosecutions.  This Administration has no problem in taking aggressive positions in the legal arena and I would expect...

On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 25 under the Syrian Sanctions Regulations, marking a measured but far-reaching reconfiguration of U.S. economic policy toward Syria. Acting in close coordination with the Department of State’s issuance of a national security waiver under Section 7425 of the Caesar Syria Civilian Protection Act of 2019...

As in every Administration, the Trump Department of Justice has made clear its enforcement priorities — government fraud, immigration and national security to include tariff and trade violations.  DOJ fully recognizes the power of the False Claims Act as  a powerful enforcement tool when it comes to trade and tariff enforcement.  Add to the mix, the well-established whistleblower or qui tam relator program and you...

 DOJ’s new Corporate Enforcement Program is designed to bring certainty to the voluntary disclosure and cooperation process.  DOJ’s intent is clear — voluntary disclosure is likely to lead to a declination, reduced penalties and the absence of a corporate monitor.  DOJ’s changes are another attempt to spur voluntary disclosures.  Over the last ten years, DOJ has step-by-step sought to increase the benefits of voluntary disclosure. ...

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...

OFAC means what it says — in more ways than one.  In a precedent setting case, OFAC brought its first enforcement action against an individual for violating the Global Magnitsky Sanctions Regulations. In 2017, OFAC implemented regulatory sanctions derived from the Global Magnitsky Act and its associated Executive Order.  The 2017 Executive Order 13818 declared a national emergency with respect to serious human rights abuses...

C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba conducted by five of its non-U.S. subsidiaries. Over a period of more than three years, these five subsidiaries provided freight brokerage or transportation services for 82 shipments, to or from Iran, of Iranian- or...