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    Nov. 19, 2025

How Tariff Evasion Heightens False Claims and Anti-Corruption Risks

Unpredictable and oft-changing tariff developments in the United States continue to dominate recent news cycles and underscore the challenges faced by U.S. importers and their supply chain partners, including increased risks of possible tariff evasion schemes. The current environment is ripe for heightened risks arising throughout the supply chain for foreign-origin merchandise imported into the U.S., and thus importers should exercise caution, conduct appropriate due diligence and carefully monitor their networks for these risks. In this guest article, Venable partners George Kostolampros, Ashley Craig and Elizabeth Lowe examine those risks and provide an overview of common tariff evasion schemes, the FCPA’s connection to tariff evasion prosecutions, and the host of other federal statutes available to meet the DOJ’s enforcement goals. See “Assessing the Criminal Division’s New Enforcement Focuses” (Jun. 18, 2025).

Matthew Galeotti on the LiMu Declination and What to Expect in FCPA Enforcement

In 2025, there have been significant changes in DOJ policies toward FCPA enforcement in particular, and white-collar enforcement in general, but case studies of how companies will be treated have been somewhat thin on the ground. Comments from a top DOJ official in September and October 2025 shed light on what enforcement might look like as this tumultuous year comes to a close. At both the Annual Pharmaceutical and Medical Device Ethics and Compliance Congress and in a speech given in New York City, Acting Assistant AG Matthew Galeotti, the current Head of the DOJ’s Criminal Division, touted Liberty Mutual’s August 2025 declination as an example of how the current DOJ plans to move ahead with enforcement and offered predictions on what to expect in the months to come. This article synthesizes his remarks. See “Zaglin Conviction Offers Insights on Individual Prosecutions in Trump 2.0” (Oct. 22, 2025).

Insights From Antitrust Enforcers on an Evolving Landscape

Compliance professionals have a lot on their plates. They must monitor global regulatory regimes that touch on bribery, corruption, fraud and abuse, and often have responsibility for things like data privacy and artificial intelligence governance. At SCCE’s 24th Annual Compliance & Ethics Institute, present and former enforcers from the DOJ’s Antitrust Division reminded practitioners that compliance with antitrust laws deserves their attention, as well. This first article in a two-part series synthesizes commentary on the current state of antitrust enforcement, covering both the basics of antitrust law and recent updates such as the Division’s new whistleblower program. The second article will examine common antitrust compliance red flags and DOJ expectations for compliance programs. See “How Anti-Corruption and Antitrust Enforcement Align” (Jan. 22, 2020).

Using the Kirkpatrick Model to Measure Healthcare Compliance Training Effectiveness

Healthcare compliance officers must be able to determine whether employee training has been effective and identify any gaps in learning. During a panel at the 26th Annual Pharmaceutical and Medical Device Ethics and Compliance Congress, experts used the Kirkpatrick Model to evaluate trainings at four different levels: reaction, learning, behavior and results. This article summarizes their insights and offers tips on using this model to assess training program effectiveness. See our three-part series “Rethinking Click-Through Training”: The Pluses and Minuses (Feb. 26, 2025), Maximize Effectiveness With Customization (Apr. 9, 2025), and Integration Into a Comprehensive Training Program (May 7, 2025).

CPPA’s Tractor Supply Decision Offers Lessons As Enforcement Focus Moves From Education to Deterrence

The California Privacy Protection Agency (CPPA), in its recent landmark decision against national rural lifestyle retailer Tractor Supply Company, imposed the largest fine in the agency’s history and marked its first case addressing privacy notices and rights for job applicants. The action contains important compliance insights for all U.S. companies, not exclusively for those operating in California. This article discusses the implications of the Tractor Supply decision, including its signaling of the CPPA’s enforcement focus, guidance on responding to regulators and practical lessons for privacy compliance. See our two-part series on emerging issues in workplace privacy: “Data Collected and Employees’ Perspectives” (Nov. 6, 2024), and “Regulations and Compliance Strategies” (Nov. 20, 2024).

Sidley Adds Former Federal Prosecutor in New York

Sidley has announced that former federal prosecutor Matthew Podolsky has joined as a partner in the firm’s white collar defense and investigations practice, as well as its commercial litigation and disputes practice in New York. He most recently served as the acting U.S. Attorney for the Southern District of New York. For insights from Sidley, see “Present and Former SEC Officials Discuss Strategy, Testimony, Proffers and Negotiations” (Mar. 12, 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.