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    Aug. 13, 2025

The FCPA Lives: Protecting American Interests

The guidance on how the DOJ will enforce the FCPA during the second Trump administration, as described in a memorandum issued by Deputy AG Todd Blanche (Blanche Memo), details how the law can be used as a sword to cut down cartels and transnational criminal organizations (TCOs). However, it also describes the ways in which the DOJ may use the FCPA as a shield for American companies and industries against global competitors. This second article in a three-part series examining the Blanche Memo unpacks the directives to protect U.S. companies, use the FCPA to advance U.S. national security, and only investigate and prosecute the most serious misconduct. The first article discussed how the DOJ plans to use the FCPA to target the full TCO ecosystem. The final part will discuss what the Blanche Memo says about corporate responsibility. For more on the DOJ’s enforcement priorities, see “Assessing the Criminal Division’s New Enforcement Focuses” (Jun. 18, 2025).

From CEO Deepfakes to AI Slop, AI Incident Tracking Ramps Up

After years of eye-opening statistics about cybersecurity attacks, it is artificial intelligence (AI) incidents’ turn to be tracked and tallied. The AI Incident Database (AIID), a research effort, has compiled reports on 1,140 publicly disclosed AI-related incidents, classified into 23 types of harms and risks. The Organisation of Economic Cooperation and Development runs another, mostly automated tracker that has added an average of approximately 330 AI incident reports per month to its database this year. Additionally, in April, the non-profit MITRE launched an AI incident-sharing site that incentivizes companies to confidentially report model tampering, adversarial data injections, voice cloning and other malicious acts targeting AI systems. This article presents observations by leaders at MITRE and AIID on the maturity of AI incident tracking, how to define what counts as an AI incident, incident trends and the benefits of AI incident information sharing. See “Cybersecurity and AI Are Top Global Business Challenges Identified in Kroll Study” (Jul. 16, 2025).

Eight Tips for Building a Cross-Company Compliance Network

In-house compliance professionals need to be able to rely on support from elsewhere in the company, but garnering that support can take effort. To engage busy managers within the organization, compliance professionals must find practical methods for catching their attention and earning their trust. This article provides eight practical tips on how to build support for compliance throughout the company, with insights shared by panelists during a recent webinar hosted by Ground Truth Intelligence. See “Survey Finds Increased Value in Having a Culture of Compliance” (Feb. 26, 2025).

How Health Organizations Can Navigate 2025’s Enforcement Shifts

Compliance professionals in the healthcare space currently face a range of enforcement shifts - some more subtle and gradual than others. The current administration is maintaining active enforcement of the Anti-Kickback Statute, the False Claims Act and the Stark Law, which targets physicians referring patients to healthcare providers with which they have a financial relationship. However, there have been nuanced changes in how the statutes are enforced by agencies such as the DOJ, the Centers for Medicare & Medicaid Services and the Office of the Inspector General of the Department of Health and Human Services. This article distills insights from a recent webinar hosted by the Health Care Compliance Association on what all this means for healthcare compliance professionals. “The Continued Value of Healthcare Compliance Guidance Amid Sector Shifts” (Feb. 26, 2025).

Staying Current on Third-Party CSR Risks

Amid changing expectations regarding environmental impact and exploitative labor practices in companies’ value chains, managing risks at third parties – including vendors, consultants, sales agents, distributors, brokers and even customers - can be time-consuming. During PLI’s recent Compliance & Ethics Essentials conference, experts discussed how companies can stay on top of the corporate social responsibility risks as part of their third-party risk management programs. This article synthesizes insights from their conversation. See “When and How to Audit Foreign Third Parties” (Apr. 23, 2025).

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Women to Watch: Contributions, Achievements and Observations of Outstanding Female Professionals

To mark International Women’s Day, women editors and reporters at ION Analytics interviewed outstanding women in the industries and jurisdictions we cover. In this part, Law Report Group editors Jill Abitbol, Robin L. Barton and Megan Zwiebel profile notable women in data privacy, cybersecurity, private funds and anti-corruption law, including Anne-Gabrielle Haie, Jessica Lee, Micaela McMurrough, Laura Perkins, Amanda Raad, Madelyn Calabrese, Ranah Esmaili and Genna Garver. Enjoy reading their inspiring remarks here.