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).

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