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    Jun. 17, 2026

Ultra Electronics: Cooperation Leads to a Second Chance at a DPA

In 2025, the SFO issued guidance outlining its expectations for companies seeking a DPA. Until recently, that guidance was merely theoretical, with DPAs thin on the ground. However, a recent settlement with Ultra Electronics Holdings Ltd, a British defense and security company, indicates that the U.K. enforcer is back in the game. This first installment in a two-part series on the case examines the company’s self-report and cooperation in the SFO’s investigation. The second part will analyze how Ultra Electronics cleaned up its compliance program and ultimately paid limited penalties, partially due to its failure to win business through paying bribes. See our two-part series on the 2026 U.K. enforcement outlook: “Compliance Evaluation Guidance” (Feb. 11, 2026), and “A Whole-Government Strategy to Fight Corruption” (Feb. 25, 2026).

Operating in Venezuela: Additional Risks and Mitigation Strategies

While the operating environment in Venezuela remains characterized by elevated and persistent risk, this challenging environment does not foreclose the possibility of responsible engagement where appropriate safeguards are in place. In the first installment of this two-part guest article series about doing business in Venezuela, Miller & Chevalier members Matteson Ellis and James Tillen, with counsel Collman Griffin and visiting law clerk Angelo Márquez, provided historical context for the current risk environment and discussed two of the most significant risk areas in the country: corruption and sanctions. In this second article, they discuss some additional areas of risk and provide strategies for mitigating them through each stage of operations in Venezuela. For more from Miller & Chevalier, see “High Risks, Low Institutional Trust: Why Stronger Anti‑Corruption Laws Do Not Guarantee Increased Reporting of Corruption in Latin America” (Aug. 14, 2024).

Perfectus’ Settlement of Qui Tam Civil Suit Is a Harbinger of Increased Tariff Enforcement

California-based Perfectus Aluminum and five of its associated companies reached a civil settlement with the DOJ (Civil Settlement), in which the aluminum importer agreed to pay $549.5 million for customs duty evasion, the largest customs award in False Claims Act history. The Civil Settlement is a harbinger of increased customs enforcement to come as President Trump’s second administration continues to push its America First Trade Policy and tariffs. This article lays out the background of the case and what it means for future enforcement, and offers compliance lessons for import programs. See “How to Prepare for an Increase in Customs Whistleblowers” (Mar. 11, 2026).

Using AI and Other Analytics Tools to Glean Insight From Hotline Data

In today’s compliance environment, hotline data is a strategic risk asset. It can be used not only to trigger investigations and resolve complaints, but also to review and revise a company’s compliance program, as well as identify and mitigate actual and emerging risks. However, many companies do not optimize the use of this data, and doing so depends more on data discipline and hygiene than the analytics tool that is used. At the March 2026 Data Analytics for Compliance Programs conference, hosted by the Society of Corporate Compliance and Ethics and featuring experts from Microsoft Corporation and Saber Healthcare Group, a panel delved into how to analyze hotline data using AI and other tools to better anticipate, identify and respond to compliance issues. This article distills the panelists’ insights. See “International Views on the Role of AI in Compliance Investigations” (Feb. 11, 2026).

AI Agent Security: What CISOs and GCs Need to Know to Defend the Enterprise

AI agents introduce an array of threats to companies distinct from those arising with traditional software. In multiple ways, agents expand the attack surface that organizations must defend. This article, the second in a two-part series on real-world security for AI agents, provides an action plan for chief information security officers (CISOs) and lawyers to strengthen security and reduce risks around AI agents, with expert perspectives from agent security specialists at Barndoor, Gravitee, Gray Swan, Skyflow and ZwillGen. Part one discussed corporate benchmarks revealed in three reports on actual incidents involving agents, and the safeguards and security measures that companies have begun to apply to agents. See “The Data Analytics and AI Transition in Compliance” (May 6, 2026).

Morgan Lewis Expands Global Investigations Capabilities

Paul Feldberg has joined Morgan Lewis as a partner in the global investigations and sanctions practice in London. He arrives from Brown Rudnick. For commentary from Feldberg, see “Ultra Electronics: Cooperation Leads to a Second Chance at a DPA” (Jun. 17, 2026).

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