Episode 397 — LRN’s Program Effectiveness Report
LRN’s 2026 Ethics & Compliance Program Effectiveness Report, titled “The Next Leap: Technology, Trust, and the Transformation of Compliance,” surveys over 2,500 compliance professionals and employees worldwide. The study reveals that while compliance programs are increasingly sophisticated and tech‑enabled, many firms struggle to convert those investments into measurable cultural or risk‑management gains. Progress is evident but uneven across regions and industries. The report serves as a benchmark for the evolving compliance landscape amid rapid regulatory and technological change.
BIS Fines Thermal Camera Exporter $1 Million for China Export Violations: De Minimis Miscalculations and Compliance Gaps
The U.S. Bureau of Industry and Security fined Teledyne FLIR $1 million for 19 Export Administration Regulations violations, chiefly misapplying the de minimis rule to thermal camera exports bound for China and Hong Kong. The company undervalued U.S.-origin components, excluded lenses from product valuations,...
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...
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...
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....
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...
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...
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...
