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    Aug. 12, 2026

A Primer on Trade Controls for Compliance Professionals: The Enforcement Landscape

At the beginning of the second Donald Trump presidential administration (Trump 2.0), there was a sense that white-collar and corporate enforcement might be on the decline, particularly when enforcement of the FCPA was paused by executive order in February 2025. At the same time, the America First Trade Policy issued on the first day of Trump 2.0 signaled a renewed focus on – and zeal for – enforcing trade controls, making corporations and individual white-collar defendants far from safe. This second article in a four-part series on trade controls for compliance professionals addresses the expanding enforcement environment, outlining the key regulators, their emerging priorities and the consequences of violations. Part One defined and differentiated the various trade controls at enforcers’ disposal. Future installments will explore where companies face trade control risks and how compliance programs should adapt to the new risk landscape. See “2025 in Review: White-Collar Enforcement the ‘Right Way’ Remains a Priority” (Dec. 17, 2025).

Adapting Compliance Programs to Manage Criminal and Civil FTO Risk

While any dealings with transnational criminal organizations (TCOs) were always risky for a multinational company (doing business with criminal organizations is usually bad for business in the long run), the U.S. Department of State’s designation of many TCOs as foreign terrorist organizations (FTOs) triggers additional laws that can have serious consequences. The Anti-Corruption Report recently spoke with Rebecca (Becky) Rohr, who most recently served as CCO and head of investigations at Telefonaktiebolaget LM Ericsson, a multinational telecommunications company headquartered in Stockholm, Sweden. This article highlights Rohr’s insights on how companies can adjust their compliance programs to address these emerging areas of risk, based on her in-house experience as well as her time as a leader and prosecutor in the DOJ’s Criminal Fraud Section. See “The Importance of Human Intelligence in Mexico to Combat FTO Risk” (Jul. 15, 2026).

Bosch Gets First NSD Declination Under Unified CEP

Robert Bosch GmbH, a German multinational engineering and technology company, has reached a settlement with the DOJ’s National Security Division (NSD) that includes the NSD’s first declination (Declination) under the DOJ’s Department-wide Corporate Enforcement Policy. On the same day, the Department of Commerce’s Bureau of Industry and Security announced its own settlement with Bosch (BIS Order). This article analyzes the Declination and BIS Order, including their implications for export controls compliance, with expert analysis from Foley Hoag, MoloLamken and Miller & Chevalier. See our two-part series on the unified CEP: “One Policy to Rule Them All?” (Apr. 8, 2026), and “The VSD Calculus” (Apr. 22, 2026).

CFTC’s 2026 Cooperation Policy: Requirements and Safe Harbors

In May 2026, the Commodity Futures Trading Commission (CFTC)’s Division of Enforcement (Division) announced a new policy (Policy) regarding cooperation on the part of individuals and organizations that might face an enforcement action. The Policy aims to clarify the Division’s stance on cooperation, taking a more consistent approach and fostering greater understanding of the potential consequences of self-reporting, remediation, restitution and/or disgorgement. This first article in a two-part series summarizes the Policy and its cooperation safe harbors. Part two will compare it to the superseded February 2025 Enforcement Advisory and other agencies’ cooperation policies, assess its potential impact and provide practical takeaways. See “Obligations Linger Despite Freepoint’s Settlements With DOJ and CFTC” (Aug. 28, 2024).

Insights From SAP on Using Data Analytics for Sanctions Compliance

In the sensitive and fast-changing field of sanctions, driven by today’s shifting geopolitical environment, data analytics can help take compliance to the next level. Compliance professionals can harness ever-more diverse data sources to build a clearer picture of a company’s risk, SAP chief legal counsel Keith Huffman explained during a panel hosted by the Society of Corporate Compliance and Ethics. This article addresses how companies can use data analytics to improve their sanctions compliance efforts, distilling insights from Huffman and fellow SAP export controls and sanctions professionals Anisa Makarova and Maria Balan. See “Thoughts From DOJ Experts on Using Data Analytics to Strengthen Compliance Programs” (May 22, 2024).

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