Corruption Crime & Compliance

Anik A. Shah is Director & Sr. Legal Counsel, Anti-Bribery and Anti-Corruption, at Sandisk, a global semiconductor manufacturer. Anik has more than 15 years of compliance, investigations, regulatory, and law enforcement experience. Anik started his career at the U.S. Securities and Exchange Commission (SEC), where he investigated anti-fraud, anti-bribery, and other violations by multi-national...

Each year, LRN’s Ethics & Compliance Program Effectiveness Report provides one of the most useful snapshots of the global compliance profession. The 2026 report— “The Next Leap: Technology, Trust, and the Transformation of Compliance” —again offers valuable insight into how corporate ethics and compliance programs are evolving amid rapid technological change, new regulatory expectations, and s...

The Commerce Department’s Bureau of Industry and Security (BIS) has sent an unmistakable message to the semiconductor industry: creative interpretations of the Export Administration Regulations (EAR) will not shield companies from significant enforcement risk. BIS imposed a $252 million penalty against Applied Materials — the second-largest fine in the agency’s history — for illegally exporting se...

Episode 395 of Corruption, Crime and Compliance features an in-depth conversation with Bob Lemmond, the new CEO of LRN, on the evolving role of ethics and compliance in today’s risk environment. In this episode, Bob discusses how organizations can move beyond “check-the-box” compliance to embed a culture of integrity that drives performance, mitigates misconduct risk, and strengthens stakeholder t...

FCPA enforcement in 2025 was defined by what did not happen as much as what did. Compared to prior years, the number of publicly announced cases declined sharply, corporate resolutions were fewer, and the overall enforcement posture appeared more restrained. This slowdown, however, reflects a policy recalibration—not a dismantling—of the FCPA enforcement regime . Early in the year, DOJ paused FCPA...

Earlier this year, the Securities and Exchange Commission (SEC) charged Archer-Daniels-Midland Company (ADM) and three of its former executives with accounting and disclosure fraud, in what has become one of the most significant financial reporting enforcement actions of 2026. The case underscores a fundamental compliance truth: strong internal controls and transparent disclosures are not optional...

Conflicts of interest are not abstract compliance niceties. They are serious risks to integrity that, if left unidentified or unmitigated, can erode employee trust, compromise decision-making, and expose organizations to regulatory enforcement, litigation, and reputational harm. Recent high-profile scandals involving relationships between supervisors and subordinates have underscored how personal...

The Justice Department has increased False Claims Act prosecutions, reflecting a continued focus on healthcare fraud and a new initiative on trade fraud. DOJ announced the largest annual recovery figure in the FCA's history -- $6.8 billion in settlements and recoveries.    FCA whistleblowers filed a record number of new cases -- 1,297 lawsuits and the government initiated 401 invest...

From my perspective, hopefully a reasonable one, there is a little too much AI-Risk Hype. Not to belittle the experts or ignore potential risk concerns but this is getting a little carried away.    The compliance industry appears to be taken over by AI-this and AI-that. Third party risk bleeds into major AI risks, corporate governance needs to incorporate AI risks, and policies...

The most significant compliance and enforcement issue remains trade enforcement -- sanctions and export controls. In the second posting, I want to focus on the new and interesting development in this area: the use of the False Claims Act to capture violations of tariffs and customs duties.   With all the hype on the trade compliance front, when you calculate the numbers relating to crimi...

Scott Greytak, Transparency International, and Nate Sibley, Hudson Institute, join Michael Volkov for a review of anti-corruption issues and a look forward to the next year.

Tom Fox joins Michael Volkov to discuss ethics and compliance issues for the year 2025. Tom and Mike focus on the importance of ethics, conflict of interest, trade compliance, organizational justice and other issues. This is Part 2 of a 2-Part Episode.

Tom Fox joins Michael Volkov to discuss ethics and compliance issues for the year 2025. Tom and Mike focus on the importance of ethics, conflict of interest, trade compliance, organizational justice and other issues. This is Part 1 of a 2-Part episode.

What do you do when the headlines shift faster than your risk matrix can keep up? In this episode, Michael Volkov dives into the challenge of adapting compliance programs in the face of volatile and fast-changing global risks—from tariffs and trade controls to supply chain disruptions and third-party exposures. While the pressure to react is constant, the real key is staying anchored in your compa...

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...

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 expec...

AI promises efficiency, innovation, and new opportunities - but are companies moving too fast in the rush to adopt it? The risks are very real, from false content to flawed decision-making, and the global regulatory patchwork is only getting more complex. The challenge now is building governance and compliance frameworks that keep pace without stifling progress.  In this episode of Corruption, Cr...

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...

Is your internal reporting program keeping up or falling behind the curve? With over 2.15 million reports analyzed from nearly 70 million employees worldwide, NAVEX's 2025 Regional Whistleblowing & Incident Management Benchmark Report offers a goldmine of insight into how companies are (and aren’t) managing employee concerns. In this episode, Michael Volkov breaks down the key findings, region...

A competitor could trigger a federal investigation against your company, just by filing a whistleblower complaint about your imports. In this episode, Michael Volkov explores how the Trump Administration is reshaping the enforcement landscape by linking trade compliance and the False Claims Act (FCA) in unprecedented ways. With “trade and customs fraud, including tariff evasion” now a DOJ national...

What happens when companies ignore red flags, bypass legal advice, and underestimate the reach of U.S. export laws? In this episode, Michael Volkov unpacks two major enforcement actions from the Department of Commerce’s Bureau of Industry and Security (BIS) and the Treasury Department’s Office of Foreign Assets Control (OFAC). These cases serve as cautionary tales for companies navigating complex...

Could your supply chain be funding cartels without you realizing it? In today’s complex global economy, companies are grappling with a dual challenge - the urgent need to unravel their supply chains and the immediate recalibration of due diligence systems to detect links to cartel and transnational criminal organizations (TCOs). With the Department of Justice sharpening its focus on both direct pr...

What happens when a company inherits a sanctions violation through acquisition, and acts fast to fix it? Can a robust post-acquisition response really save a parent company from prosecution? In this episode, Michael Volkov unpacks the fascinating DOJ-led global enforcement action against UNICAT Catalyst Technologies - a case that reflects the U.S. government's intensifying focus on trade enforceme...

Are your trade compliance programs truly airtight - or are they just good enough to get caught? In this episode, Michael breaks down why tariff and trade violations are now squarely on DOJ’s radar, and why the heat is rising fast for importers, especially those dealing with Chinese goods. With enforcement priorities shifting, companies are at increased risk of both regulatory investigations a...

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...