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FCPA Compliance Report

FCPA Compliance Report – FCPA Enforcement Shifts: Volatility and Uncertainty

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode,  host Tom Fox welcomes Anik Shah, Director & Senior Legal Counsel at Sandisk, for an insightful discussion about the pivotal changes and enforcement actions around the FCPA in 2025 and their implications for 2026.

In 2025, Anik Shah, a preeminent authority on FCPA and anti-corruption enforcement, offers a strategic perspective on the evolving compliance landscape. Given the recent uncertainties following an executive order and the dismissal of high-profile cases, Shah underscores the necessity for companies to maintain robust anti-bribery and anti-corruption controls, especially with potential reprioritization by the Department of Justice. He advocates a proactive risk management approach, emphasizing the importance of third-party risk management and comprehensive training to anticipate and mitigate potential FCPA issues. As enforcement focus shifts toward addressing cartel and transnational criminal organization activities, Shah advises companies to integrate anti-money laundering processes into their compliance strategies to align with global anti-corruption efforts.

Key highlights:

  • 2025 FCPA Enforcement Shifts and Uncertainty
  • Voluntary Self-Disclosure Policy Revolution in 2025
  • Cartel Risk Mitigation through Compliance Integration
  • Central Asia Construction Projects: Anti-Corruption Measures
  • Proactive Measures: Fostering Anti-Corruption Compliance Awareness

Resources:

Anik Shah on LinkedIn

Sandisk

Tom Fox

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Innovation in Compliance

Innovation in Compliance – Insights on FCPA and Anti-Corruption Enforcement Trends with Anik Shah

Innovation touches every part of the modern enterprise, and compliance professionals must be prepared not only to respond to change but to lead through it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators on the award-winning Innovation in Compliance podcast. In this episode, host Tom Fox welcomes Anik Shah, Global Director of Anti-Bribery and Anti-Corruption Compliance at Sandisk, for an insightful discussion on the pivotal shifts in FCPA enforcement during 2025 and what they signal for 2026.

Shah outlines his extensive professional background, including his prior roles at the SEC and DOJ. The conversation explores key developments from 2025, including the Executive Order pausing certain FCPA investigations, the Blanche Memo’s four criteria for opening FCPA cases, and the implications of revisions to the Corporate Enforcement Policy. He also analyzes the Communications Cellular enforcement action to highlight practical compliance lessons, focusing on strengthening AML controls, managing third-party risk, and deploying proactive compliance measures amid renewed anti-corruption scrutiny.

The episode concludes with a forward-looking discussion of emerging anti-corruption risks associated with advanced AI technologies, large AI construction projects, and related permitting activities, both in the United States and globally. Shah offers strategic recommendations for compliance professionals seeking to anticipate and manage these evolving risks.

Key highlights:

• 2025 as a Pivotal Year in FCPA Enforcement

• The Blanche Memo and Corporate Enforcement Policy Revisions

• Anti-Money Laundering and Third-Party Risk Management

• Large AI Construction Projects and Permitting Risks

• Global Anti-Corruption Laws and Compliance

• Key Takeaways for 2026

Resources:

Anik Shah on LinkedIn 

Sandisk

Innovation in Compliance was recently honored as the Number 4 podcast in Risk Management by 1,000,000 Podcasts.

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ACI FCPA Conference 2025

ACI-FCPA Conference Speaker Preview Series – Anik Shah on Lawyering Through These Uncertain Times

In this episode of the ACI-FCPA and Global Anti-Corruption Conference Speaker Podcasts series, Anik Shah discusses his panel at the event, “Lawyering Through Uncertainty: The New Reality of Advising Clients and Making Decisions in Unchartered Territory.”

Some of the issues the panel will discuss are:

  • Navigating current client dilemmas;
  • Risk Assessments and Internal Investigations;
  • Recalibrating your compliance program for 2026 and beyond.

I hope you can join me at the ACI–FCPA Conference. This year’s event will take place on December 3-4 at the Gaylord National Resort & Convention Center in National Harbor, Maryland, near Washington, D.C. The lineup of this year’s event is simply first-rate, featuring some of the top FCPA professionals, white-collar attorneys, and compliance practitioners in the field.

The 2025 program is being completely redesigned to help your organization stay agile, responsive, and ahead of the curve. Expect a dynamic agenda shaped by real-world priorities, practical takeaways, and the most cutting-edge thinking in compliance—led by a faculty of global practitioners with boots on the ground, encountering the very risks that come across your desk.

Please join me at the event. For information on the event, click here. Listeners of this podcast will receive a discount by using the code D10-999-CPN26.