Mike & Brent connect the dots between the Administration’s signals regarding U.S. export control enforcement, recent media reports, and how trade compliance teams can best prepare for what comes next. They discuss the overall climate of uncertainty (01:03), an April 8, 2025 report by Reuters about a potential large U.S. export controls fine in the works (01:35), how companies can best respond to a counterparty being put on the U.S. Bureau of Industry & Security’s “Entity List” (05:47), how to respond to U.S. government outreach or administrative subpoenas (07:27), an April 10, 2025 report by Export Compliance Daily about a potential uptick in administrative subpoenas (11:39), their prior “Fresh Looks” post on responding to government inquiries (13:51), and conclude with another installment of Brent Carlson’s “Managing-Up” (17:38).
In Episode 4, Mike and Brent revisit another of their prior “Fresh Looks” posts on the NYU Law School’s Program on Corporate Compliance & Enforcement (“PCCE”) blog. This one concerns export control penalties and what to make of recent statements attributed to Commerce Secretary Howard Lutnick and Undersecretary Jeffrey Kessler. Mike and Brent discuss the context for the original November 14, 2023, post (00:30), how historical FCPA penalties compared to U.S. export controls penalties prior to the April 2023 Seagate resolution (01:26), what current official statements and enforcement trends mean for c-suites and boards (02:59), a recent Export Compliance Daily article regarding internal BIS discussions about enforcement priorities (04:57), how to prepare (07:23) for high probability-based enforcement (08:52), the role of the DOJ’s National Security Division (11:01), and conclude with Brent Carlson’s “Managing Up” segment (12:30).
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast on compliance. In this episode, Tom welcomes Tim O’Toole and Matt Ellis from Miller & Chevalier Chartered to discuss the significant implications of President Trump’s executive order designating Mexican drug cartels as foreign terrorist organizations (FTOs).
Tim and Matt elaborate on the heightened compliance risks and operational challenges now faced by companies operating in these regions. The conversation delves into the legal distinctions between Specially Designated Nationals (SDNs) and FTOs, the broad-ranging impact on industries such as agriculture and logistics, and the urgent need for robust risk assessment strategies to mitigate civil and criminal liabilities under U.S. law. They also explore the broader Latin American context and potential collateral consequences for U.S. and Latin American companies amid anticipations of increased regulatory scrutiny and enforcement actions. The discussion concludes with timely observations on recent U.S. Treasury directives aimed at curbing cartel money laundering activities, showcasing the lengths the administration is willing to go to combat these criminal enterprises.
What happens when two top compliance commentators get together? They talk compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s episode!
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes back Mike Huneke and Brent Carlson for a special two-part podcast series on DeepSeek’s bombshell AI advancements announced on President Trump’s inauguration day. In Part 1, they review the business and compliance implications, and in Part 2, they consider the Sputnik Moment that has occurred.
In Part 1, they consider the immediate and significant repercussions in both the business and compliance landscapes. Key topics include the economic and geopolitical ramifications of DeepSeek’s innovations, changes in export control policies, and the unique compliance challenges AI technology poses. The discussion also examines how corporations can recalibrate their risk frameworks, integrate high-probability standards, and leverage data analytics to handle millions of transactions in a global economy. Emphasizing the importance of comprehensive compliance programs, the episode provides actionable insights for compliance professionals navigating this evolving landscape.
Welcome to the award-winning FCPA Compliance Report, the longest-running compliance podcast. In this episode, Tom welcomes back Brent Carlson and Mike Huneke to discuss a crucial topic in corporate compliance: the return on investment (ROI) in export controls compliance.
This pod reviews the challenges compliance professionals face in articulating the value proposition for investments in compliance programs. Brent and Mike highlight the misconceptions about compliance being merely a cost center and explore various ways to demonstrate its tangible benefits to executive teams and boards. The discussion also covers the impact of recent regulatory changes and geopolitical tensions and how companies can proactively address these shifts to ensure robust compliance and leverage new opportunities. By looking at past enforcement actions and drawing parallels with the evolution of the FCPA, the episode provides listeners with critical insights into the practical steps for enhancing compliance programs and the importance of staying ahead of regulatory expectations in a rapidly changing global trade environment.
Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News—all from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.
What happens when two top compliance commentators get together? They talk compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s episode!
In this episode of the ‘Two Gurus Talk Compliance Podcast,’ hosts Kristy Grant-Hart and Tom Fox delve into recent updates and stories in the compliance world. They explore the DOJ’s latest guidance on corporate compliance programs, highlighting themes of data access and the role of AI. Discussion on domestic bribery leads to the case against NYC Mayor Eric Adams for alleged violations, including unauthorized travel expenses. The hosts also analyze four significant trade sanction cases detailed by Michael Volkov, illustrating the importance of rigorous compliance measures. Notable segments include the investigation into Binance’s hefty compliance investments, the influence of competition on corporate culture, and current issues in internal controls. A curious case on Caremark claims against Wells Fargo’s board is mentioned, providing insights into potential legal trends. The podcast closes with a humorous touch on a Florida man’s recurring jail visits due to retail fraud. The episode is a comprehensive overview of key compliance topics marked by real-world examples and expert insights.
Stories Include:
How Binance found that old time ‘compliance’ religion. (WSJ)
David Caruso is the founder and managing director of the Dominion Advisory Group, a consulting firm based in Virginia, near the nation’s capital. The firm works with banks facing regulatory enforcement actions across the U.S., Europe, and Asia. David aids institutions and organizations in navigating financial crime risk and compliance modernization globally.
As a former special agent with the US Secret Service and a graduate of George Washington University since 1996, he has been at the forefront of shaping the financial crime risk and compliance profession more generally. Building anti-money laundering (AML) and sanctions compliance programs at banking and financial institutions across the US and internationally, overseeing headline-grabbing corruption and money laundering investigations, and building and selling a RegTech software firm have afforded him an ideal perspective to reflect on every major issue and trend occurring in the financial crime compliance space for the past 25 years.
In this episode of Regulatory Ramblings, David shares his reflections on a nearly three-decade career in AML and financial crime compliance with our host, Ajay Shamdasani.
He recounts having worked at global institutions like JP Morgan, Riggs Bank, Wachovia, Washington Mutual, and HSBC, to name a few. His notable achievements include his time as Riggs Bank’s chief compliance and AML officer.
In that role, he was hired to address some program weaknesses cited by the US Treasury Department’s Office of the Comptroller of the Currency (OCC). While at Riggs, David’s team uncovered two notorious international corruption schemes involving the government of Equatorial Guinea and former Chilean dictator Augusto Pinochet. The team’s work led to investigations by the Department of Justice and the U.S. Senate Permanent Subcommittee on Investigations.
The cases drew worldwide media attention from justice authorities in the US, UK, Spain, and Chile. The facts uncovered by David at Riggs shook US lawmakers and regulators, kicking off 10 years of active regulatory and law enforcement action against banks across the US.
After Riggs, David founded The Dominion Advisory Group in 2005. From his ringside seat near Washington, DC, he works closely with executive management, boards, and outside counsel to craft responses and build entire financial crime risk and compliance programs to address regulatory concerns—of which there has been no shortage in recent years.
David also discusses the allure of AML and financial crime compliance and what brought him to the professional path he has been on for over three decades. Methodologically speaking, he recounts what has changed in AML and financial crime in that time and what has remained the same.
He concurs that since 1970, so many additional requirements and expectations have been created that AML teams still need to catch up on their primary mission. Reflecting on the impact of the Bank Secrecy Act (1970), the USA PATRIOT Act (2001), the Foreign Account Tax Compliance Act (2010), or FATCA, and the more recent Anti Money Laundering Act (2020), he shares his views on how the impact of regulatory action has distracted from compliance professionals’ more critical tasks—with an eye towards how the regulatory exam-focused mindset of money laundering reporting officers (MLROs) affects operations and innovation.
David also depicts the pervasive and ongoing discrepancies between what domestic and international/supernational policy-setting organizations, like the Financial Action Task Force (FATF), based in Paris, say and what they do. He says, “No one wants to ask if new rules and regulations are working and whether they prevent crime or have the unintended consequence of reducing [economic] growth?”
He acknowledges the degree of geopolitical hypocrisy when it comes to AML and financial crime compliance, as well as when it comes to fighting bribery, fraud, and corruption internationally. Washington, New York, London, and Brussels all too often regulated the financial world. Yet, while the US and UK, and increasingly the EU, are some of the most aggressive jurisdictions regarding financial crime enforcement actions, their regulatory apparatus is often used to further their geopolitical goals. It is a view that many outside the West hold.
The conversation concludes with David’s views on why sanctions against Russia stemming from its 2022 invasion of Ukraine have largely been unsuccessful, how technologies such as artificial intelligence can help AML/KYC/FCC compliance, and what policy recommendations he suggests moving forward.
We are bringing you the Regulatory Ramblings podcasts with assistance from the HKU Faculty of Law, the University of Hong Kong’s Reg/Tech Lab, HKU-SCF Fintech Academy, Asia Global Institute, and HKU-edX Professional Certificate in Fintech.
Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee and listen to the Daily Compliance News. All from the Compliance Podcast Network.
Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.
In today’s edition of Daily Compliance News:
The Senate says BMW used forced labor on car parts. (NYT)
