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Corruption, Crime & Compliance

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Beyond the Checklist: Why Effective Conflicts of Interest Programs Are Central to Ethics and Compliance

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 ...


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

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 contro...


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Episode 392 — The Importance of Managing Conflicts of Interests

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 ...


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The Tilt Toward Corporate Voluntary Disclosures

Companies often face difficult choices when it comes to deciding on whether to disclose corporate misconduct to the government. Over the years, more counsel have embraced the idea of sitting tight after uncovering and remediating misconduct (unless the company is subject to mandatory disclosure requirements).

Admittedly, I have been aware of situations where tha...


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UFLPA Enforcement: When a "Red Light” Turns Yellow

The Uyghur Forced Labor Prevention Act (UFLPA) was designed to be one of the toughest trade enforcement statutes ever enacted by Congress. Passed with near-unanimous bipartisan support in late 2021, the law created a rebuttable presumption that goods made wholly or in part in China’s Xinjiang region—or by entities linked to forced labor there—are prohibited from entering ...


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