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Corruption, Crime & Compliance

Corruption, Crime & Compliance

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Enforcement updates and corporate compliance guidance from a former federal prosecutor.

Recent Posts

FCPA Enforcement in 2025 (Part I of II): A Slowdown, a Policy Reset, and What the Numbers Really Mean
News•Feb 19, 2026

FCPA Enforcement in 2025 (Part I of II): A Slowdown, a Policy Reset, and What the Numbers Really Mean

In 2025, FCPA enforcement slowed dramatically, with fewer publicly announced cases and no new SEC actions. The DOJ paused investigations early in the year and issued revised guidance that emphasizes selectivity toward high‑impact bribery and national‑security concerns. Despite the overall slowdown, major cases still produced substantial penalties, including a deferred prosecution agreement exceeding $100 million. Enforcement infrastructure—whistleblower pipelines, international cooperation, and accounting controls—remains fully operational, indicating a policy reset rather than a retreat.

By Corruption, Crime & Compliance
When Conflicts Become Compliance Crises: SEC and DOJ Enforcement Lessons From the Real World
News•Feb 18, 2026

When Conflicts Become Compliance Crises: SEC and DOJ Enforcement Lessons From the Real World

Regulators are treating conflicts of interest as operational threats rather than abstract compliance check‑boxes. Over the past 18 months the SEC has levied multi‑million penalties on advisers for undisclosed incentive structures, while the DOJ has pursued criminal cases where personal...

By Corruption, Crime & Compliance
Episode 393- When Financial Controls Fail: The SEC’s ADM Settlement and the Cost of Misleading Investors
News•Feb 16, 2026

Episode 393- When Financial Controls Fail: The SEC’s ADM Settlement and the Cost of Misleading Investors

The SEC charged Archer‑Daniels‑Midland (ADM) and three former executives with accounting and disclosure fraud, culminating in a landmark 2026 enforcement action. ADM was found to have materially overstated its nutrition segment by recording intersegment transactions on non‑market terms, inflating profitability....

By Corruption, Crime & Compliance
Episode 392 — The Importance of Managing Conflicts of Interests
News•Feb 11, 2026

Episode 392 — The Importance of Managing Conflicts of Interests

Conflicts of interest are increasingly recognized as critical compliance risks that can undermine employee trust, skew decision‑making, and expose firms to litigation and reputational damage. Recent scandals involving supervisor‑subordinate relationships illustrate how personal ties can cascade into enterprise‑wide failures when...

By Corruption, Crime & Compliance
The Tilt Toward Corporate Voluntary Disclosures
News•Feb 10, 2026

The Tilt Toward Corporate Voluntary Disclosures

Under the Trump administration, the DOJ has refined its corporate enforcement policy to more actively reward voluntary disclosures of misconduct. Companies that promptly self‑report, fully cooperate, and remediate can receive declinations and potentially avoid disgorgement, as illustrated by recent False...

By Corruption, Crime & Compliance
UFLPA Enforcement: When a “Red Light” Turns Yellow
News•Feb 9, 2026

UFLPA Enforcement: When a “Red Light” Turns Yellow

The Uyghur Forced Labor Prevention Act, enacted in 2021, created a rebuttable presumption that Xinjiang‑origin goods are barred from the U.S. market. U.S. Customs data show a sharp drop in UFLPA‑related detentions, from roughly $1.58 billion in 2023 and $1.40 billion in...

By Corruption, Crime & Compliance