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Ghost turns his focus to Jules Kroll, the man once dubbed the “CIA of Wall Street.” The episode traces Kroll's rise from cleaning up corporate graft in New York to building Kroll Associates, a private intelligence powerhouse that hired ex-CIA and FBI operatives and shaped global investigations. Ghost unpacks Kroll's ties to NewsGuard, its role in blacklisting independent media, and how its lead investor funnelled money into firms like Flashpoint that work with the FBI to target so-called “domestic extremists.” The discussion connects Kroll to Robert Maxwell, one of the last people to meet with him before his death, and to 9/11, where his firm ran World Trade Center security after the 1993 bombing. Ghost also highlights how Kroll's reach extended into Russian asset hunts under Yeltsin, kleptocrat cases from Marcos to Baby Doc, and the creation of a corporate intelligence industry built on secrets. With references to Trump's pause on FCPA enforcement, the Foreign Corrupt Practices Act, and the blurred lines between private intelligence and government psyops, this chapter reveals how deeply Jules Kroll's shadow runs through finance, geopolitics, and narrative warfare.
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, we discuss President Trump's review of other interests in US business and its implications for compliance. The panel explores the evolving landscape of government involvement in major U.S. corporations and the resulting compliance and anti-corruption risks. With recent actions by the Trump administration to acquire stakes or exert control over companies like US Steel and Intel, the discussion centers on the implications for FCPA enforcement, the definition of “instrumentality,” and the challenges facing compliance professionals as the boundaries between public and private sectors blur. The episode also examines international perspectives, potential conflicts of interest, and the impact on global business relationships. Key highlights: Introduction: Are We Becoming Socialist? Golden Share and Control Mechanisms Anti-Corruption Risks and FCPA Instrumentality International Law and Foreign Supplier Risks Conflicts of Interest and Board Representation International Perspectives: UK and EU Compliance Politically Exposed Persons and Due Diligence Closing Thoughts: Navigating Uncharted Territory Resources: Matt Kelly in Radical Compliance Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the use of AI in Compliance programs, my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the Great Women in Compliance podcast with Hemma Lomax and Lisa Fine, sponsored by Corporate Compliance Insight and a part of the Compliance Podcast Network. My guest today isn't really a guest, she's so much more. She is an architect of GWIC, my first partner in compliance, and my first compliance friend who is still a dear friend. She coined the phrase “Send the Elevator Back Down,” taught me about tall poppy syndrome, and I am still using her cheat codes. Of course, it's Mary Shirley! Mary, can you update everyone on all the cool things going on since you became, as we call it #GWICemerita? As a global compliance leader, who has lived in several countries and now three very different states in the US, what do you see as the principles of a "culture of integrity" that apply to any business, regardless of geography or industry? · While there has been change in US laws, particularly the FCPA, and newer laws in the EU and the UK, among others, are you seeing any shifts how to define – or ommunicate – a culture of integrity? · You have put together a list of questions for job seekers to ask about terms of compliance programs and a culture of integrity. What do you think is the most revealing one and why? o Mine is “can I talk to my predecessor?” I will be seeing you very soon at SCCE CEI. You and Matt Kelly are presenting “AI Governance for N00bs: A Beginner's Guide for the Non-Tech Compliance Practitioner” on Sunday[LF1] to kick things off. · What do you see as the biggest opportunities for compliance professionals to use AI and machine learning? · What challenges do you see for integrating AI and machine learning into their compliance program, and how should we approach it? o What about the algorithmic bias? · It seems like ethics and compliance are being welcomed as "partners" at the AI governance table. What do you think is the most significant reason for this shift, and what can a compliance professional do to ensure they maintain that strategic seat at the table? When you think about the first 200 episodes, do you have a specific non-substantive, non-podcast memory that sticks out to you? Besides the origin story – which I still tell! [LF1]Right between the end of the Buffalo Bills game and cocktails - perfect timing ☺️
Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News. All, from the Compliance Podcast Network. Each day, we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest that are relevant to the compliance professional. Top stories include: War Hero and corrupt Congressman dies. (NYT) The world will need oil and the FCPA for a long, long time. (NYT) The great state of Texas is MAHA. (FT) Texas says Chinese can't own land in Texas. (BBC) Linda Ronstadt Long, Long Time on YouTube Learn more about your ad choices. Visit megaphone.fm/adchoices
With the beginning of the “New FCPA” era coined by DOJ's Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just the same as FCPA legal requirements. 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 and supply sides and outlines appropriate strategies to manage these risks.Epsilon Electronics serves as a stark reminder of the financial consequences of non-compliance. The company faced an OFAC enforcement action due to a shipment to Iran, resulting in a staggering penalty of over $4 million.Apollo Aviation Group settled with OFAC for $210,600 for leasing aircraft engines which ultimately ended up being placed in to aircraft of a prohibited entity, Sudan Airways, violating sanctions regulations.ELF Cosmetics settled with OFAC for $996,000 for importing false eyelash kits containing materials sourced from North Korea, highlighting supply chain due diligence failures.The ELF Cosmetics case underscores the crucial role of supply chain due diligence in preventing sanctions violations. Instead of sticking their heads in the sand, companies must undertake basic supply chain due diligence when sourcing products from regions close to high-risk countries or regions.“Reason to know” is now the key phrase guiding the New FCPA era. OFAC does not need to prove goods ultimately end up in a sanctioned country. When you see red flags, you must resolve them or they could be considered a “reason to know” in OFAC's eyes.Seven essential elements to boost your compliance program and effectively mitigate third-party sanctions risks include risk assessment, varying levels of due diligence, end-user documentation, monitoring, training, and red flag identification.ResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
In this episode of ‘From The Editor's Desk' podcast, hosts Tom Fox and Aaron Nicodemus delve into key compliance issues featured in Compliance Week. They discuss the heightened risks for companies doing business in Mexico due to connections with cartels, recent enforcement actions stemming from these connections, and the Trump administration's first FCPA bribery case. They also preview an upcoming case study on Lafarge's operations in Syria and introduce new website features, including CW Connect, designed to foster meaningful conversations among compliance officers. Additionally, they highlight best practices and preview articles planned for National Compliance Officer Day. Highlights include: Top Compliance Stories in August 2025 Risks of Doing Business in Mexico FCPA Enforcement Actions and Investigations Upcoming Case Study on Lafarge Website Redesign and New Features Resources: Aaron Nicodemus on LinkedIn Compliance Week
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 should expect, and why individuals are squarely in the crosshairs. Taken together, these cases remind listeners that while priorities may shift, the fundamentals of disclosure, cooperation, and accountability remain very much alive.You'll hear him discuss:Why Liberty Mutual's $4.7 million disgorgement shows DOJ is sticking closely to its Corporate Enforcement PolicyHow voluntary disclosure and cooperation continue to all but guarantee a declinationThe details behind Liberty Mutual's misconduct in India and the factors DOJ weighed in its decisionWhat the Pemex indictment tells us about DOJ's push to hold individuals accountableThe role of disgorgement in DOJ resolutions and whether the policy might be applied with more flexibility going forwardHow luxury goods and personal perks were used in the Pemex scheme and why DOJ zeroed in on those detailsWhat these developments signal for companies trying to strengthen compliance programs in a shifting enforcement landscapeResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group's podcast, All Things Investigation. In this podcast, host Tom Fox welcomes back Mike DeBernardis to discuss the recently released first Foreign Corrupt Practices Act (FCPA) enforcement action, a Declination involving Liberty Mutual Insurance Company. Mike DeBernardis, partner at Hughes Hubbard & Reed, and Tom delve into the first FCPA enforcement action of 2025 involving Liberty Mutual. They discuss the nuances of self-disclosure during ongoing investigations, the challenges facing defense attorneys, and the expectations set by the new corporate enforcement policy. Key topics include proactive cooperation, dealing with deconfliction, and the importance of root cause analysis. The conversation provides valuable insights into how the Department of Justice communicates its expectations through enforcement actions and the evolving landscape of corporate compliance. Key highlights: Exploring the Liberty Mutual Case Challenges of Early Self-Disclosure Corporate Enforcement Policy Changes Full and Proactive Cooperation De-confliction in DOJ Investigations Root Cause Analysis Importance Social Media and Ephemeral Messaging Resources: Hughes Hubbard & Reed website Mike DeBernardis
In this episode, John Byrne and Elliot Berman unpack a series of significant developments in banking, compliance, and enforcement. They begin with the White House's new executive order on “Guaranteeing Fair Banking for All Americans,” which aims to prevent what some call “debanking.” While positioned as a fairness measure, John and Elliot warn that it could weaken banks' ability to make independent, risk-based decisions, potentially increasing white-collar crime exposure. They note concerns over the subjective nature of risk scoring and parallels to the 2008–2010 financial crisis. Next, they spotlight the IRS-CI “CI-FIRST” program, a collaborative effort between financial institutions and the IRS's Criminal Investigation division to improve information sharing and streamline financial record requests. The recent CI-FIRST Executive Forum in Washington is seen as a model for effective public-private partnerships in combating financial crime. The discussion then turns to enforcement actions: Paxos Trust Company will pay $26.5 million to New York regulators for failing to properly vet Binance and for systemic AML program weaknesses, alongside a $22 million investment in compliance upgrades. The DOJ issued its first corporate FCPA action since resuming enforcement, with Liberty Mutual paying $4.7 million to resolve bribery allegations involving Indian state-owned banks. Do Kwon, co-founder of Terraform Labs, pled guilty to wire fraud and conspiracy, tied to the $40 billion collapse of Terra USD and Luna, with a $19 million penalty and possible 12-year sentence. They also cover a Senate minority report critical of the administration's approach to Russian sanctions, arguing it undermines Ukraine's leverage and lacks consistent enforcement. The FACT Coalition emphasizes the need for tools like the Corporate Transparency Act to bolster sanctions' effectiveness. On the policy front, they discuss delays and staffing cuts affecting the State Department's annual human rights report and the pending trafficking in persons report—both key references for global human rights and anti-trafficking efforts.
What happens when a company tries to outsmart the system - and gets caught red-handed by the DOJ in a $140 million export control scheme tied to Chinese military supercomputers?In this episode, Michael dives into the DOJ's criminal enforcement action against Cadence Design Systems - a case that marks yet another major step in the DOJ's rapidly unfolding trade enforcement strategy. We're no longer in the FCPA era. This is a whole new ballgame, where national security and trade compliance have collided, and companies that haven't adjusted are already behind.You'll hear him discuss:Why Cadence's plea deal - not a DPA or NPA - is such a big dealHow the DOJ and BIS coordinated to secure over $140 million in criminal and civil penaltiesThe simple, sloppy scheme that involved fake names, hidden aliases, and blatant attempts to skirt export controlsWhy partial cooperation didn't earn Cadence a full credit reduction - and what they failed to doThe shocking compliance gap: only one export control officer handling global riskWhat this case signals about the DOJ's growing focus on national security and semiconductor enforcementWhy ethics, due diligence, and transaction monitoring are still your best defenseHow companies can avoid getting blindsided by embracing the new trade enforcement landscapeResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
In this week's episode, Joe McNamara and John Byrne examine significant shifts in the regulatory landscape, starting with a tribute to compliance leader Anna Rentschler. They dive into concerning changes to FCPA enforcement guidance that critics say abandons universal ethical standards, the OCC's unusual LinkedIn post signaling increased risk tolerance for banks, and growing threats to the Corporate Transparency Act. The discussion moves internationally to cover the UK's crypto asset sanctions compliance findings, the EU's latest money laundering risk assessment highlighting fintech vulnerabilities, and an FBI advisory on the Scattered Spider cybercriminal group.
Monday July 7, 2025 Mike Koehler on FCPA Prosecutions Under Trump
Episode #73 with Christopher Cottrell, Richard Butler and Haider Mannan
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Today, Tom Fox welcomes Ellen Lafferty, a well-known figure in the compliance community with a distinguished career in both financial and educational institutions. Ellen discusses her new book, ‘Anti-Bribery and Corruption Law and Compliance In a Nutshell,' detailing what inspired her to write it and how it can serve as a comprehensive reference for both legal and compliance professionals. They explore Ellen's transition from litigator to in-house compliance officer, emphasizing the importance of understanding the ultimate audience in legal advice. They also discuss the implications of recent changes in FCPA enforcement priorities by the U.S. government as of 2025 and how compliance professionals should adapt. Ellen emphasizes the importance of maintaining rigorous compliance programs and provides practical guidance on conducting self-assessments and gap analyses to ensure robust anti-bribery and corruption measures. Key highlights: Ellen Lafferty's Career and Book Inspiration Transition from Litigator to Compliance Officer Scope and Audience of the Book Current Compliance Landscape in 2025 Advice for Compliance Professionals Resources: Ellen Lafferty on LinkedIn West Academic Publishing Anti-Bribery and Corruption Law and Compliance in a Nutshell on Amazon Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the use of AI in Compliance programs, my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
Has the pendulum swung back on FCPA enforcement - and will companies be ready when it hits? Is the DOJ's renewed push on FCPA enforcement a strategic shift - or just old wine in a new bottle?In this episode, Michael discusses the return of the Justice Department to the FCPA enforcement arena. In a significant development, DOJ announced the resumption of FCPA enforcement, accompanied by a new set of enforcement guidance principles. This guidance is more than policy - it's a statement of priorities and strategy that will shape how FCPA investigations and prosecutions unfold. While the number of attorneys in DOJ's FCPA Unit has declined, U.S. Attorneys' Offices across 94 districts now have increased authority to investigate and prosecute FCPA cases with less oversight. The result? Potentially broader, faster, and more decentralized enforcement. As always, the devil is in the details - and the June 9 DOJ FCPA Guidance Memo delivers plenty.You'll hear him discuss:DOJ's renewed emphasis on prosecuting individuals over corporations, especially when misconduct can't be directly linked to senior leadershipHow companies may now have stronger arguments to avoid liability if the wrongdoing is isolated to a small groupExpanded autonomy for U.S. Attorneys' Offices and what this means for enforcement volume and consistencyThe DOJ's prioritization of cases that directly impact U.S. national interests and corporate competitivenessIncreased scrutiny of links to cartels and transnational criminal organizations, including risks hidden in supply chains and third-party relationshipsThe push for faster, more efficient investigations to avoid the years-long white-collar case backlogGuidance on when facilitating payments, gifts, or travel fall under FCPA exceptions - and why these rarely matter in major prosecutionsWhy cooperation, early disclosure, and individual accountability may now be companies' best bet for avoiding charges altogetherThe DOJ's sharpened focus on national security sectors like defense, critical infrastructure, and technologyResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
Have you ever wondered how some people stay optimistic, even during the most uncertain times? And somehow still manage to manifest the Porsche they always dreamed of? In this episode of It's a Mindset, I'm joined by the wise and joyful Danette Fenton-Menzies: Director of Learning at Magical Learning, host of Adapt with Danette FM, and author of The Adaptable Leader. With over 30 years of experience spanning CFO roles, executive coaching, and leadership across both public and private sectors, Danette brings a powerful blend of brain science, heart-centred leadership, and practical tools to help you stay grounded, joyful, and opportunity-focused, no matter what life throws your way. We cover everything from visualising big goals and managing stress to the surprising lessons Danette learned from being coached by the legendary Robin Sharma (yes, that Robin Sharma!). She even shares how she manifested her dream Porsche by her 40th birthday, through visualisation, aligned action, and a mindset of possibility. This is a rich, uplifting conversation that reminds us that joy isn't something we find after the hard season, it's something we choose all the time. Key Episode Takeaways: How to lead and communicate with more love and kindness, especially in family-run businesses The importance of seeing people's innate gifts and empowering those around you Why asking “What's the opportunity?” is a powerful mindset shift during uncertain times How nervous system regulation, presence, and joy lead to better decision-making The value of rest and reflection, like taking quarterly breaks (holidays) to recharge Why intentionality and surrender are key to achieving your goals (even the Porsche you've been dreaming of). Show Resources: Connect with Danette on LinkedIn - HERE Follow Magical Learning on Instagram - HERE Check Out Magical Learning on YouTube - HERE Follow Emma, the Podcast Host on Instagram - HERE Check Out Emma's Book, Worthy & Wealthy - HERE About the Guest: Danette is Director of Learning for Magical Learning and author of The Adaptable Leader: 7 skills to help you succeed during uncertainty, and podcast host of Adapt with Danette FM. She is a Certified Master Trainer and Coach: Intelligent Leadership® Executive Coaching, a Chartered Accountant, FCPA and has over thirty years' experience in both the private and public sectors including CFO at SafeWork Australia. She works with global family businesses, corporates and government. She uses the latest brain science and tools to help leaders adapt faster and optimise opportunities while navigating uncertainty. If you LOVED this episode, share it on your Instagram stories and tag us @emmalagerlow and @magical_learning, we'd love to hear what inspired you! Your in the Joy of Learning, Emma. X.
The U.S. has been policing bribery all over the world for nearly half a century using a law called the Foreign Corrupt Practices Act. But now, President Trump has said that this anti-corruption law is crippling American businesses. Since taking office, his administration has reduced the number of investigators, killed some cases, and changed the rules.In this episode, we look at the FCPA case against Glencore, a large commodity trading company, found guilty in 2022 for paying cash bribes in exchange for lucrative contracts all over the world.And we go back to the inception of the law, a time when using bribes to pay off foreign officials was considered "grease in the wheels" - a reasonable (if unethical) way to get business done.This episode was hosted by Amanda Aronczyk and Erika Beras. It was produced by Willa Rubin. It was fact-checked by Emily Crawford with help from Willa Rubin. It was edited by Marianne McCune. It was engineered by James Willetts. Alex Goldmark is Planet Money's executive producer.Find more Planet Money: Facebook / Instagram / TikTok / Our weekly Newsletter.Listen free at these links: Apple Podcasts, Spotify, the NPR app or anywhere you get podcasts.Help support Planet Money and hear our bonus episodes by subscribing to Planet Money+ in Apple Podcasts or at plus.npr.org/planetmoney.Learn more about sponsor message choices: podcastchoices.com/adchoicesNPR Privacy Policy
Fastest 5 Minutes, The Podcast Government Contractors Can't Do Without
This week's episode covers developments involving the Foreign Corrupt Practices Act, and is hosted by Peter Eyre and Alex Kramer. Crowell & Moring's "Fastest 5 Minutes" is a biweekly podcast that provides a brief summary of significant government contracts legal and regulatory developments that no government contracts lawyer or executive should be without.
Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group's podcast, All Things Investigation. In this episode of ‘All Things Investigations,' host Tom Fox is joined by Mike DeBernardis to discuss the recent guidelines released by Deputy Attorney General Todd Blanche on the enforcement of the Foreign Corrupt Practices Act (FCPA). They dissect the new memorandum, its implications for corporate investigations, and the focus on eliminating cartels and transnational criminal organizations. The conversation also delves into topics such as competitive advantage, the role of national security in FCPA enforcement, and the strategic implications for companies. The episode concludes with insights on how companies and their legal counsel should navigate these updated guidelines and prepare for a more expedited and focused investigation process. Key highlights: Overview of New FCPA Guidelines Focus on Competitive Advantage Prosecutorial Considerations National Security and Strategic Business Prioritizing Serious Misconduct Advising Clients on FCPA Compliance Resources: Mike DeBernardis Hughes Hubbard & Reed website HHR Client Alert: DOJ Ends FCPA Enforcement Pause
Machalagh Carr is a trusted and discreet counselor with decades of private sector and government experience. She has nimbly navigated the intersection of congressional investigations and oversight, law, geopolitics, international anticorruption measures, and policy, and served as the top staffer in Article I as Chief of Staff to Speaker of the House Kevin McCarthy. She is the Founder & CEO of Quell strategies, a boutique consulting firm where she helps client navigate Washington and translates the intricacies of public policy to the business world. Prior to her role as Chief of Staff, she served as General Counsel for the Speaker and Office of the Republican Leader at the U.S. House of Representatives. Previously, she served as General Counsel & Parliamentarian for the Committee on Ways and Means, where she handled all legal and procedural issues for the Committee. Before that, she was the Oversight Staff Director at the Committee where she led the investigations and oversight of all issues within the Committee's jurisdiction, served as the Director of Oversight and Investigations for the Committee on Oversight and Government Reform and as Senior Oversight Counsel at the Committee on Natural Resources. Prior to her public service, Machalagh served in the Office of Global Compliance of an international energy company where she conducted internal anti-corruption investigations, audits, and compliance reviews for the company, including expertise in FCPA, and UK Bribery Act. She also practiced in the Litigation, White Collar, and Government Investigations Group at Sonnenschein Nath and Rosenthal LLP (now Dentons). She currently serves as the Head of Global Policy for Palantir Technologies. Directly after law school, Machalagh clerked for the Chief Judge of the U.S. Court of Appeals for the Armed Forces. She taught Trial Practice at Catholic University of America, Columbus School of Law, is a Politics and Public Service Fellow at Georgetown University McCourt School, and lives in Virginia with her husband and three sons.
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. Today, I welcome back James Tillen and Ann Sultan, both partners at Miller & Chevalier. We take a deep dive into four recent DOJ Policy announcements: FCPA Enforcement, White Collar Enforcement, Criminal Enforcement Policy and Whistleblower Pilot Program. New DOJ Policy Memorandum We take a deep dive into Deputy Attorney General Todd Blanche's Memo on Investigations and Enforcement of the FCPA. We review the stated main goals of the DOJ and how are prosecutors supposed to achieve these goals. We consider the 3 directives to prosecutors: focus on cases with individual misconduct, proceed expeditiously, consider collateral consequences. We look at the White Collar Plan and CEP and ask if we moved from a presumption of a declination to a more tangible framework? We conclude by reviewing what compliance professionals need to be thinking about and looking into now. Key Highlights IncludeHow does the principle of "not attribute[ing] nonspecific malfeasance to corporate structures" impact potential prosecutions of companies and individuals? And how do these priorities jive with other DOJ priorities, such as prosecuting cartels/transnational criminal organizations? What does it mean for companies that the DOJ is prioritizing “serious misconduct”? What are the implications of the DOJ's stated intent to avoid penalizing “routine business practices in other nations”? Do you see this as a shift in focus for the DOJ to non-US companies? Other DOJ Priorities & Announcements Policy Shifts and Clarifications Looking Ahead: What's on the Horizon Resources FCPA Spring Review 2025 – Miller & Chevalier DOJ Criminal Division White Collar Plan Guidelines for Investigations and Enforcement of the FCPA Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the use of AI in Compliance programs, my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com Learn more about your ad choices. Visit megaphone.fm/adchoices
Hui Chen is a luminary in the world of Ethics and Compliance, and she is our guest on today's episode of Great Women in Compliance. Today, Hui is one of the co-founders of CDE Advisors, which stands for “Culture. Data. Ethics.” Most of us know Hui from her work at the Department of Justice (DOJ) and her contributions to the Evaluation of Corporate Compliance for the Fraud Section. However, my career path included being a prosecutor, in-house compliance work, and even being inspired to pursue a Master's degree in Divinity after the 9/11 attacks. Hui discusses the origins of the ECCP and her perspective on its current use. She also discusses the opportunity in the “FCPA pause” and how organizations can broaden their ethical considerations beyond foreign bribery to focus on relationships with all stakeholders. She discussed how the focus on regulatory guidance, particularly on bribery outside the United States, is just one of many areas to consider as a compliance professional. She also offers practical advice based on her experiences working with global compliance functions and the lessons she has learned.
Key Takeaways:Maintain Tone at the Top: Boards should confirm that their commitment to compliance and ethical behavior remains strong and consistent, even with the DOJ's pause on new FCPA investigations. This includes consistent messaging throughout the organization. Review Third-Party Risk Management: Companies should reassess their third-party risk management programs to make sure they are not inadvertently engaging with entities associated with transnational criminal organizations (TCOs) or terrorist organizations. Refresh Risk Assessment: Boards should ask management to perform a thorough risk assessment, with an intentional focus on operations. Geographical Focus: Companies should evaluate the culture and increased risk in regions where they operate, to maintain compliance and mitigate risks associated with these areas. Revisit Whistleblower Processes: Boards should ask to be kept appraised of all whistleblower reports and resolutions. Independent Investigations: In cases where there is a potential threat or pressure to pay a bribe, boards should facilitate independent investigations, involving outside counsel and forensic accountants to maintain objectivity and thoroughness. Related Resources:FCPA Compliance: A Practical Guide for Identifying and Mitigating the Risk of Violations
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent memorandum from the Deputy Attorney General regarding the investigation and enforcement of the FCPA. The memo follows President Trump's executive order pausing FCPA enforcement for six months. The hosts evaluate the potential impacts on compliance programs, with a possible shift to targeting foreign companies that harm US business interests and national security. They also explore the role of the Foreign Extortion Prevention Act and speculate on how the SEC might integrate these changes into its enforcement practices. Key highlights: Initial Reactions to the FCPA Memo Implications for Anti-Corruption Compliance Focus on Foreign Companies and National Security Skepticism and Potential Bias in Enforcement Strategic National Interests and Enforcement Considerations for Compliance Officers Resources: Memo on Guidelines for Investigation and Enforcement of the FCPA Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices
What if your trade compliance misstep became tomorrow's federal prosecution headline? In this episode, Michael Volkov issues a powerful warning to corporate leaders and compliance professionals: the DOJ is no longer treating trade violations as minor infractions—they're targeting them as fraud under the False Claims Act. With trade compliance now framed as a national security issue, this administration is on a mission to protect domestic industries and punish companies that cut corners. If your organization engages in international trade—especially with China—this episode is a must-listen.You'll hear him discuss:Why corporate leaders should not confuse the pause in FCPA enforcement with a wider drop in corporate prosecutions, as the DOJ is intensifying its focus on other high-risk areas like customs and trade complianceHow the False Claims Act is being used to prosecute companies for tariff evasion, misclassification of goods, and country-of-origin fraud, creating major new exposure for import-heavy businessesThe administration's positioning of trade compliance as a national security priority, which signals tougher penalties and more aggressive enforcement tacticsExamples of recent DOJ cases, including multimillion-dollar settlements with Barco Uniforms, International Vitamins Corporation, and Danco Laboratories, that highlight how quickly companies can become targetsThe expanding role of whistleblowers under new DOJ incentives, making it more likely that internal missteps will be reported and investigatedWhy supply chains involving China and other flagged jurisdictions are under heightened scrutiny, and how companies can prepare for increased oversightThe risks of becoming a public example of trade fraud, and the steps companies should take now to stay ahead of enforcement and protect their brand and bottom lineResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
What happens when the world's most influential anti-bribery law is abruptly paused? Is transparency merely a compliance box-tick—or the most powerful tool we have against global threats like kleptocracy, sanctions evasion, and illicit finance? In this eye-opening episode of Corruption, Crime, and Compliance, Michael Volkov is joined by two powerhouse experts in the global fight against corruption: Scott Greytak and Josh Birenbaum (*see ‘'About Guests below). Together, they break down the sweeping implications of the U.S. government's pause on Foreign Corrupt Practices Act (FCPA)enforcement, the gutting of the Corporate Transparency Act (CTA), and what all of this means for business leaders, policymakers, and the international community.When the United States hit pause on FCPA enforcement, the global anti-corruption landscape shifted. Scott and Josh explore how companies are reacting, how allies are stepping up enforcement, and why transparency is emerging as a national security imperative. They offer a forward-looking conversation filled with insights for compliance professionals, risk officers, and anyone committed to ethical business in a volatile world.You'll hear them discuss:Why the U.S. government's pause on FCPA enforcement shocked the global anti-corruption community—and why companies should still stay the course with compliance regardless of political signals.How the Corporate Transparency Act, once seen as the most significant U.S. anti-money laundering law in a generation, has been quietly gutted—leaving a dangerous gap in the fight against shell companies and financial crime.What it means that U.S. companies are now incentivized to form anonymously domestically to avoid ownership disclosure—inviting kleptocrats, traffickers, and foreign adversaries to hide in plain sight.Why global businesses must prepare for a sharp rise in trade compliance enforcement, as tariffs, export controls, and sanctions take center stage in economic security—and why transparency is essential to managing these risks.How foreign enforcers, especially in Europe, are beginning to step up—but why no alliance or coalition can truly fill the vacuum left by a retreating United States.What makes transparency not just a compliance tool, but a weapon against geopolitical threats—from Xinjiang's forced labor camps to Russian shadow fleets and fentanyl trafficking.How transparency can be hardwired into foreign aid policy to protect U.S. taxpayer money, prevent narco-state development, and give American businesses a fair shot abroad.Why there's still hope—from new bipartisan support for anti-corruption measures to the emergence of a national security lens on transparency across Congress, federal agencies, and the private sector.About GuestsScott Greytak is an anticorruption attorney and the Director of Advocacy for TI US. His work focuses on designing anticorruption laws and policies, organizing and leading ideologically inclusive coalitions, and lobbying the U.S. Congress and administration. Greytak was named a Top Lobbyist in 2021, 2023, and 2024 by the National Institute for Lobbying & Ethics. Josh Birenbaum is the deputy director of FDD's Center on Economic and Financial Power, focusing on illicit finance risks and global corruption. Previously, Josh was the research and policy analyst at TRACE International, producing articles, book chapters, op-eds, model policies, industry reports, and speeches on sanctions, export controls, corruption, conflict minerals, money laundering, human rights, illicit finance, and other topics. ResourcesScott Greytak on LinkedIn | Email - sgreytak@us.transparency.orgJosh Birenbaum on LinkedIn | Email - jbirenbaum@fdd.orgMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
By Adam Turteltaub Uzbekistan, Kazakhstan, Tajikistan, Turkmenistan and Kyrgyzstan were all born out of the dissolution of the Soviet Union. With large energy deposits of national gas, many global companies and their suppliers are operating within these countries. To better understand the compliance risks there, we spoke with Timur Khasanov-Batirov, a compliance officer with deep and wide roots in the region. While we may think of this area as one region, he warns that there are substantial differences by country. Kazakhstan is the most developed, and compliance has gained significant traction in large companies, primarily in the oil and gas sector. Uzbekistan saw three major FCPA cases, and, as a result, compliance has garnered a great deal of attention. The other three countries have much smaller economies and less developed compliance cultures. In addition, Turkmenistan has a fairly-closed economy, which complicates the picture. While it is easy to focus on the anticorruption risk in the region, there are other challenges. The area has become a significant transshipment point to Russia of prohibited and dual-use goods. In addition, child and forced labor is an issue, especially in the textile industry. To mitigate these risks, especially for sanctions evasion and corruption, companies operating in the region will need to pay close attention to the ownership of companies. That is not always easy to do because corporate structures are often opaque. The desktop-based due diligence systems in the US and Europe are likely not sufficient, Timur advises. Having someone on the ground in the region is likely needed. Listen in to learn more about what it takes to operate a compliance program in this important part of the world. Listen now
Innovation comes in many areas, and compliance professionals must be ready for and embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. Today, we begin a 3-part podcast series sponsored by Diligent with Clint Palermo, Kristy Grant-Hart, and Stephanie Font. In Part 3, Tom is joined by Kristy Grant-Hart, Vice President and Head of Compliance Advisory Services at Spark Compliance Consulting, a Diligent brand, about the state of compliance in the wake of recent changes to FCPA enforcement. They discuss the importance of staying consistent with compliance programs, the role of regulatory bodies worldwide, and the practical implications of modern slavery and trade sanctions. Kristy emphasizes the need for a strategic focus on forward-looking risks and the benefits of combining Diligent's software capabilities with expertise in compliance services. They also underscore the importance of maintaining psychological safety and a speak-up culture within organizations. Key highlights: The Importance of Consistency in Compliance The Power of Combining Compliance Services with Technology Strategic Focus for Compliance Officers Resources: Kristy Grant-Hart on LinkedIn Spark Compliance Visit Diligent Website Tom Fox Instagram Facebook YouTube Twitter LinkedIn
When The United States has hit pause on Foreign Corrupt Practices Act (FCPA) enforcement—it left many asking whether Europe will now be stepping up to lead the global anti-corruption charge. In this episode of Corruption, Crime and Compliance, Michael Volkov explores how European prosecutors are responding to the enforcement gap, why multinational companies can't afford to slow down their compliance efforts, and how both state-level and international initiatives are reshaping the future of anti-bribery law.You'll hear him talk about:The launch of a new International Anti-Corruption Prosecutorial Task Force formed by the UK, France, and Switzerland, designed to intensify cross-border enforcement and cooperation in bribery and corruption cases.The task force's formation as a direct response to the U.S. enforcement pause, signaling that European agencies are prepared to take a more prominent role in prosecuting international corruption, especially involving multinational corporations.California's bold move to pursue foreign bribery under its Unfair Competition Law (UCL), reinforcing that FCPA violations remain prosecutable at the state level despite federal hesitation.A continued commitment by global companies to maintain strong compliance programs, reflecting awareness that international and local enforcement can still pose serious legal and financial risks.The unexpected dismissal of the long-running FCPA case against Cognizant executives, contrasted with the DOJ's decision to move forward with prosecutions in other high-profile cases, suggesting a selective enforcement pattern under current policy shifts.A landmark case by the UK Serious Fraud Office (SFO), charging a company with failure to prevent bribery—a first for the SFO to bring such a case before a jury, potentially setting a new standard for corporate liability in the UK.ResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
Robert shares his formative experiences, the pivotal moments that led to the founding of his company, and the tough decisions that came along the way. He delves into topics such as the importance of resilience, making quick and decisive choices, and the evolution of leadership. 05:35 The Leap into Entrepreneurship14:34 Leadership and Accountability22:51 A Life-Changing Conversation35:19 Teaching Financial Wisdom to Kids…
Host Professor J.W. Verret interviews Pete Tomczak, global head of investigations at Baker McKenzie, about the current state of Foreign Corrupt Practices Act practice in the wake of the new administration's pause. We discuss the real world FCPA case of US v. Lawrence Hoskins, a defendant who was acquitted in a case that went to trial and saw multiple appellate decisions that demonstrates a tendency for federal overreach in FCPA matters.
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly take a deep dive into the intricate future of corporate compliance amidst changes brought by the presidential executive order suspending FCPA investigation and enforcement. Matt shares insights from a recent Compliance Week event in Boston, highlighting concerns among compliance professionals about the potential obsolescence of their roles. The discussion covers two primary scenarios: regulatory relaxation, making dedicated compliance roles redundant, and technological advancements, particularly AI, potentially replacing human compliance officers. However, both agree on the enduring importance of robust compliance functions integrated within corporate structures, emphasizing the strategic value of compliance in risk management and business operations. They explore the dual excitement and anxiety surrounding AI's role in compliance. Matt and Tom caution against shortsighted management decisions to decentralize compliance functions and highlight how AI can be harnessed to enhance rather than replace human oversight. They argue for proactive measures from compliance officers to demonstrate their value and leverage AI to improve compliance programs. As Matt eloquently puts it, this is a challenging yet opportune time for compliance professionals to up their game and secure their vital role in ensuring corporate integrity and efficiency. Key highlights: The Future of Compliance Post-Executive Order The Role of Technology in Compliance AI's Impact on Compliance Officers Strategic Imperatives for Compliance Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Hui Chen A Pause in FCPA Enforcement: Crisis or Opportunity Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of a Top 25 Regulatory Compliance Podcast Learn more about your ad choices. Visit megaphone.fm/adchoices
In this episode of Great Women in Compliance, Hemma hosts Jennifer Lee, a partner at Jenner & Block LLP and former Assistant Director at the SEC. The discussion covers Jennifer's work in SEC investigations, the importance of integrity in legal practice, and key challenges faced by compliance professionals, including evolving cybersecurity obligations and the future of FCPA enforcement. Tune in today to hear Jennifer share her insights on maintaining ethical standards, managing client expectations during investigations, and the value of community and mentorship in the legal profession. Highlights include: - How to avoid the slippery slope to enforcement - Insights on values-based decision-making from Jennifer's reading list - What our clients need most from legal and compliance counsel - Perspectives from a former federal prosecutor at the SEC - What compliance officers should be thinking about today
The Foreign Corrupt Practices Act goes back decades. It prohibits U.S. companies from bribing officials of other countries for contracts. Even if corruption is the norm in that country. Now the Trump administration says it's not enforcing the FCPA. For what this means, we turn to an attorney who's an expert in this law, Cadwalader partner Martin Weinstein. Learn more about your ad choices. Visit podcastchoices.com/adchoicesSee Privacy Policy at https://art19.com/privacy and California Privacy Notice at https://art19.com/privacy#do-not-sell-my-info.
The Foreign Corrupt Practices Act goes back decades. It prohibits U.S. companies from bribing officials of other countries for contracts. Even if corruption is the norm in that country. Now the Trump administration says it's not enforcing the FCPA. For what this means, we turn to an attorney who's an expert in this law, Cadwalader partner Martin Weinstein. Learn more about your ad choices. Visit podcastchoices.com/adchoices
In this episode of Whistleblower of the Week, host Jane Turner speaks with Stephen M. Kohn, co-Founder and Board Chairman of National Whistleblower Center and leading whistleblower attorney. On February 10th, President Trump halted enforcement of the Foreign Corrupt Practices Act (“FCPA”) in an Executive Order, arguing the move would aid American business abroad. Listen to Kohn and Turner discuss how this decision will impact American business and whistleblowers reporting bribery, corruption, and collusion. On March 13th, Kohn published an article, “Crippling the FCPA is Bad Business for the U.S” in the NYU Compliance and Enforcement Blog. He highlights his recent research which illustrates how FCPA enforcement primarily targets foreign companies, with monetary sanctions against foreign companies far outpacing sanctions against U.S-based companies. National Whistleblower Center has launched a campaign to call for the resuming of FCPA enforcements. Take action today by contacting your Representatives and Senators. Listen to the podcast on WNN or on Spotify, Apple Podcasts, Google Podcasts, or Amazon. Subscribe on your favorite platform!
This episode features a discussion between regular KB host Liz David-Barrett, and Kevin E. Davis, the Beller Family Professor of Business Law at NYU School of Law. Their conversation centres on the international regulation of bribery and corruption, specifically focusing on the U.S. Foreign Corrupt Practices Act (FCPA), following President Trump's recent suspension of its enforcement. The episode explores the potential implications for U.S. companies, foreign entities, and international anti-corruption efforts. Read Kevin's recent blog post on this issue here: https://wp.nyu.edu/compliance_enforcement/2025/02/21/implications-of-pausing-fcpa-enforcement/ And his paper on international regulation here: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4506000
Welcome to the award-winning FCPA Compliance Report, the longest-running compliance podcast. In this episode, Tom welcomes Eric Morehead to discuss the role and function of the U.S. Sentencing Commission. Eric is the Director of Advisory Services Solutions at LRN and former Assistant General Counsel at the U.S. Sentencing Commission. He and Tom review the intricacies of the U.S. Sentencing Commission's role, structure, and impact. Eric walks through his professional journey and explains the Sentencing Commission's function in standardizing federal criminal sentences and promoting organizational compliance programs. He emphasizes the importance of the Sentencing Guidelines, the process for their amendment, and the challenges faced by the Commission, such as quorum issues. The discussion also touches on current topics, including the potential impact of executive orders on DEI policies and the FCPA pause, stressing the continued relevance of the Sentencing Guidelines in compliance program development. Key highlights: Eric Morehead's Background and Role at the U.S. Sentencing Commission Understanding the U.S. Sentencing Commission Process of Creating and Amending Sentencing Guidelines Impact of Sentencing Guidelines on Compliance Programs Current Issues in Compliance: DEI and FCPA Enforcement Resources: Eric Morehead on LinkedIn LRN US Sentencing Guidelines for Organizations Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
In this episode of The Ethics Experts, Nick and Gio welcome Andrew McBride. Andrew McBride is the CEO of Integrity Bridge LLC, a consulting practice offering strategic & operational compliance support for companies. Andrew has over 25 years of compliance experience, at an international law firm and several multinational companies in the Americas, Europe and Australasia. In his most recent role as Chief Risk & Compliance Officer at Albemarle Corporation, he built a new ethics and compliance program, and recruited a new team, against the backdrop of an FCPA investigation. The investigation was resolved by way of a Non-Prosecution Agreement with the U.S. Department of Justice and Cease & Desist Order with the U.S. Securities and Exchange Commission. As part of the resolution, Albemarle secured a 45% reduction in penalty due to its co-operation with the investigation and the compliance program that was built, the largest FCPA % penalty reduction to date. In recognition of these efforts Albemarle was awarded Compliance Program of the Year by Compliance Week in May 2024. In parallel to the FCPA investigation and business ethics efforts, Andrew played a key role supporting Albemarle's commitment to sustainability including UN Global Compact membership, management of the company's human rights framework and support for the company's successful efforts to achieve certification against the Initiative of Responsible Mining Assurance (IRMA)'s Mining Standard. Prior to Albemarle, Andrew was Associate General Counsel Compliance at BHP, Senior Antitrust Counsel at BP and Managing Associate at Linklaters. Andrew is admitted to practice law in England, Western Australia & California. He is also a Certified Fraud Examiner.
Is your company prepared for the compliance storm ahead? With tariffs shaking global trade, aggressive sanctions enforcement, and new risks from AI, businesses must rethink their strategies. Can your compliance program keep up, or will it be left scrambling?In this episode of Corruption, Crime, and Compliance, Michael Volkov unpacks the rapidly shifting risk landscape facing businesses today. From trade compliance and supply chain disruptions to cybersecurity and government enforcement, he highlights the top legal and compliance challenges of the year and offers practical guidance on how companies can stay ahead. While the regulatory world is in flux, one thing remains certain—organizations that fail to adapt will face significant financial, legal, and reputational consequences.You'll hear him discuss:The evolving trade landscape, including tariff enforcement, import risks, and the potential economic fallout of aggressive trade policiesWhy supply chain mapping is no longer optional, with companies needing to identify vulnerabilities, alternative sourcing strategies, and compliance risks to avoid costly disruptionsHow businesses should approach the FCPA enforcement pause, what it signals about the government's priorities, and why global companies remain committed to anti-corruption programsWhy compliance teams must elevate import control and export control programs, particularly as the US expands restrictions on advanced computing, AI, and semiconductor exportsHow transnational criminal organizations are infiltrating legitimate supply chains for money laundering, and what companies must do to strengthen their due diligence effortsThe importance of a strong compliance culture in a time of regulatory uncertainty—how companies can remain flexible, proactive, and aligned with their core values despite the shifting landscapeResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
India's complex regulatory landscape presents significant challenges for businesses navigating anti-bribery enforcement, compliance frameworks, and evolving data privacy concerns. With shifts in global regulatory priorities — such as changes in US FCPA enforcement and the growing influence of the UK Bribery Act — companies must stay proactive in risk management. As technology, including AI and machine learning, reshapes investigations, organisations need robust compliance programmes to mitigate fraud, money laundering, and corruption risks in an evolving enforcement environment. Join host Brian Mich as he speaks with forensic expert Sushmit Bhattacharya about the intricacies of compliance and investigations in India. They discuss the impact of shifting global anti-corruption policies, the role of AI in forensic analysis, and how businesses can strengthen governance in the face of increasing regulatory scrutiny. From navigating FCPA and UK Bribery Act enforcement to handling emerging risks in data collection and privacy, this episode offers valuable insights for legal and compliance professionals operating in India. Find out more.
In today's episode, Lisa speaks with a Great Gentleman in Compliance, Andrew McBride, the CEO and founder of Integrity Bridge. Andrew shares his journey in the compliance field from private practice, to becoming Chief Compliance Officer at Albemarle, to starting Integrity Bridge. At Albemarle, Andrew built a new ethics and compliance program against the backdrop of an FCPA investigation. The work of Andrew and his team and their cooperation with the US Department of Justice, led to a decrease of 45% penalty reduction. The program was also awarded Compliance Week's “Program of the Year” award. He highlights the importance of having a multifunctional approach to building compliance programs, working closely with various departments such as sales, procurement, and finance. He also emphasizes how ethics and compliance teams are best positioned to succeed if they have different backgrounds and skill sets. Andrew shares his experience in building Integrity Bridge, a consultancy focused on helping companies design and implement holistic compliance programs to proactively use technology and address risks which are constantly evolving.
Are You Ready for the Next Wave of Corporate Risk? Corporate risks are shifting, and every board, C-suite, and compliance team must take a fresh look at their risk landscape. While some risks like cybersecurity, data privacy, and artificial intelligence remain high priorities, others—such as anti-corruption and antitrust enforcement—are evolving in unexpected ways. With regulatory changes and new enforcement priorities emerging, businesses must stay ahead of the curve to avoid costly missteps. In this episode of Corruption, Crime & Compliance, Michael Volkov unpacks the latest updates in FCPA enforcement, antitrust scrutiny, and trade compliance. With the DOJ shifting its focus, companies need to prepare for the new compliance reality.You'll Hear Him Discuss:Why companies must reassess their risk priorities in today's unpredictable business environment, as corporate risks continue to shift in response to new regulatory and enforcement trends.The impact of the FCPA enforcement pause, what it really means for global businesses, and why companies cannot afford to dismantle their anti-corruption programs despite the temporary halt in enforcement.How the DOJ is shifting its focus toward prosecuting criminal cartels and transnational organizations, and what that means for businesses operating in high-risk regions or industries.The evolving landscape of antitrust enforcement, including key takeaways from Gail Slater's confirmation hearing and how the administration's new approach may impact high-tech competition cases.How businesses should prepare for heightened tariffs, trade compliance risks, and increased customs enforcement, particularly as the U.S. targets imports from China, Southeast Asia, Mexico, and Canada.Why workplace immigration enforcement is becoming a bigger concern, with the government ramping up workplace raids, audits, and compliance checks for companies employing immigrant workers.The growing scrutiny around government grants, the potential for fraud investigations, and how businesses receiving federal funds must ensure strict compliance with evolving regulatory requirements.ResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
What happens when an entire era of anti-corruption enforcement is put on pause? Is this a strategic move to bolster American businesses or a dangerous rollback of corporate accountability? In an unprecedented move, the Trump administration has hit the brakes on FCPA enforcement for at least 180 days, citing concerns over U.S. economic competitiveness and national security. In this episode of Corruption, Crime, and Compliance, Michael Volkov breaks down the implications of this game-changing executive order. The executive order claims that FCPA enforcement has been stretched beyond its original intent, harming American businesses while benefiting foreign competitors. With the Department of Justice now ordered to reassess its approach to anti-bribery enforcement, the business and legal communities are left wondering—what happens next? Will companies adjust their compliance strategies, or will global enforcement trends keep them in check?You'll hear him discuss:The Trump administration's rationale for halting FCPA enforcement and why the decision was both surprising and expectedThe executive order's directive to the Attorney General to reassess FCPA investigations and enforcement prioritiesThe shift in DOJ focus from corporate bribery cases to prosecuting cartels and transnational criminal organizationsThe potential impact on global anti-corruption efforts, as countries like the UK, France, and Brazil continue enforcing their own bribery lawsThe uncertainty surrounding DOJ's forthcoming guidance and what companies should anticipate in the next 180 daysThe broader implications for corporate compliance programs, risk assessments, and international business strategyThe historical context of past efforts to reform the FCPA and why similar arguments were made over a decade agoThe potential for companies to seek remedial measures for past FCPA enforcement actions and the challenges in implementing such a policyHow this shift in enforcement priorities may affect corporate ethics, internal investigations, and global compliance expectationsResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
This week: Trump has signed an order suspending the enforcement of the Foreign Corrupt Practices Act. Felix Salmon, Emily Peck, and Elizabeth Spiers speculate on his motives and on how likely it actually is that this will shield anyone from the FCPA. Then, Elon Musk has taken $80 million that was sent to New York City by FEMA directly out of the city's account. The hosts discuss the legality and worrisome precedent of the move. Finally, inflation is still a thing. They go over the latest inflation report which of course leads to another Egg Watch 2025. In the Slate Plus episode: Japanese 7Elevens Want to hear that discussion and hear more Slate Money? Join Slate Plus to unlock weekly bonus episodes. Plus, you'll access ad-free listening across all your favorite Slate podcasts. You can subscribe directly from the Slate Money show page on Apple Podcasts and Spotify. Or, visit slate.com/moneyplus to get access wherever you listen. Podcast production by Jessamine Molli. Learn more about your ad choices. Visit megaphone.fm/adchoices
This week: Trump has signed an order suspending the enforcement of the Foreign Corrupt Practices Act. Felix Salmon, Emily Peck, and Elizabeth Spiers speculate on his motives and on how likely it actually is that this will shield anyone from the FCPA. Then, Elon Musk has taken $80 million that was sent to New York City by FEMA directly out of the city's account. The hosts discuss the legality and worrisome precedent of the move. Finally, inflation is still a thing. They go over the latest inflation report which of course leads to another Egg Watch 2025. In the Slate Plus episode: Japanese 7Elevens Want to hear that discussion and hear more Slate Money? Join Slate Plus to unlock weekly bonus episodes. Plus, you'll access ad-free listening across all your favorite Slate podcasts. You can subscribe directly from the Slate Money show page on Apple Podcasts and Spotify. Or, visit slate.com/moneyplus to get access wherever you listen. Podcast production by Jessamine Molli. Learn more about your ad choices. Visit megaphone.fm/adchoices
This week: Trump has signed an order suspending the enforcement of the Foreign Corrupt Practices Act. Felix Salmon, Emily Peck, and Elizabeth Spiers speculate on his motives and on how likely it actually is that this will shield anyone from the FCPA. Then, Elon Musk has taken $80 million that was sent to New York City by FEMA directly out of the city's account. The hosts discuss the legality and worrisome precedent of the move. Finally, inflation is still a thing. They go over the latest inflation report which of course leads to another Egg Watch 2025. In the Slate Plus episode: Japanese 7Elevens Want to hear that discussion and hear more Slate Money? Join Slate Plus to unlock weekly bonus episodes. Plus, you'll access ad-free listening across all your favorite Slate podcasts. You can subscribe directly from the Slate Money show page on Apple Podcasts and Spotify. Or, visit slate.com/moneyplus to get access wherever you listen. Podcast production by Jessamine Molli. Learn more about your ad choices. Visit megaphone.fm/adchoices
This week: Trump has signed an order suspending the enforcement of the Foreign Corrupt Practices Act. Felix Salmon, Emily Peck, and Elizabeth Spiers speculate on his motives and on how likely it actually is that this will shield anyone from the FCPA. Then, Elon Musk has taken $80 million that was sent to New York City by FEMA directly out of the city's account. The hosts discuss the legality and worrisome precedent of the move. Finally, inflation is still a thing. They go over the latest inflation report which of course leads to another Egg Watch 2025. In the Slate Plus episode: Japanese 7Elevens Want to hear that discussion and hear more Slate Money? Join Slate Plus to unlock weekly bonus episodes. Plus, you'll access ad-free listening across all your favorite Slate podcasts. You can subscribe directly from the Slate Money show page on Apple Podcasts and Spotify. Or, visit slate.com/moneyplus to get access wherever you listen. Podcast production by Jessamine Molli. Learn more about your ad choices. Visit megaphone.fm/adchoices
This podcast is based on TRACE's recent Year in Review webinar with Kate Atkinson. Kate is a Member and the Chair of Miller & Chevalier, based in their DC office, and she reviews for us the FCPA highlights for 2024.
Can the DOJ's commitment to holding individuals and corporations accountable under the FCPA survive the changing political climate in 2025? Will the push for innovation in corporate compliance programs be enough to maintain momentum, especially with emerging technologies like artificial intelligence? In this episode of Corruption, Crime and Compliance, Michael Volkov dives deep into the FCPA enforcement landscape of 2024, outlining key cases, changes in DOJ policies, and the evolving role of compliance programs. He highlights the significant rise in penalties and individual criminal prosecutions, as well as the continuation of major corporate settlements such as Raytheon, Trafigura, Gunvor, and SAP. The episode also explores DOJ's new whistleblower program and its continued push for companies to enhance their compliance frameworks.You'll hear him discuss:Key FCPA enforcement matters in 2024 including the Raytheon, Trafigura, Gunvor, and SAP cases.The shift in DOJ's approach, where individual prosecutions now play a larger role than ever before.The rise in penalties: 2024 saw a significant jump, with a total of $1.7 billion in fines.The return of travel, hospitality, and gifts as common bribery techniques, despite increased focus on compliance.DOJ's major industry sweeps, particularly targeting the energy commodity trading industry.The emergence of new compliance challenges with a focus on artificial intelligence and emerging technologies in corporate settings.The controversial SAP settlement and the DOJ's approach to a lack of voluntary disclosure.The impact of mergers and acquisitions on compliance processes and the integration of acquired companies.DOJ's new whistleblower program designed to incentivize individuals to report misconduct.How companies should approach merger and acquisition integration to ensure compliance and prevent risks.ResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group