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    May 6, 2026

The Overlap Between Human Trafficking and Corruption

Compliance programs often begin as a response to FCPA enforcement and other anti-bribery and anti-corruption laws, but their potential extends well beyond avoiding DOJ scrutiny. As Gwendolyn Lee Hassan, vice president and CCO at global technology solutions company Unisys, told the Anti-Corruption Report, there is a clear overlap between corruption and human trafficking, which traditional compliance frameworks are increasingly well-positioned to address. In this exclusive interview, Hassan traces her journey into compliance, explains how preventing human trafficking became a personal mission through efforts such as her podcast, Hidden Traffic, and describes how companies can leverage their compliance programs and new AI tools to strengthen ethical business practices. See “Staying Current on Third-Party CSR Risks” (Aug. 13, 2025).

Compliance Reps and Warranties: Verification and Enforcement

The phrase “trust but verify” may be an overused trope, but it has relevance in the realm of compliance representations (reps) and warranties. Even as corporations promise that they are in compliance with applicable bribery and corruption laws – and warrant that they will maintain a compliance program, policies, procedures and controls to continue to adhere to these laws – it is prudent not to take these assurances at face value. This third article in a four-part series on compliance reps and warranties looks at how a party can verify compliance and seek remedies for contract breaches. The first part in the series addressed the relevance and lifespan of compliance reps and warranties; the second article discussed negotiations; and the final installment will cover changes that should be made to these provisions as risks shift. See our series on risk assessments in Trump 2.0: “Back to Basics” (Aug. 27, 2025), “Reassessing in the Great American Reset” (Sep. 24, 2025), “Who and When” (Nov. 5, 2025), and “Employing Data and Emerging Technologies” (Dec. 31, 2025).

Balt Settlement: International Cooperation Continues

For most companies that discover anti-corruption issues after a merger or acquisition, the ultimate prize is to win a declination from the DOJ. Balt SAS, a French medical device company, achieved that goal but still faces consequences in France. The case illustrates that, even as the DOJ is increasingly likely to decline to prosecute cases that do not fit neatly into the second Trump administration’s enforcement priorities, there are still risks for individuals and corporations, in the U.S. and abroad. This second installment in a two-part series looks at the extraterritorial reach of the DOJ in FCPA cases, anti-corruption cooperation between the U.S. and France, best practices for mergers and how anti-corruption agencies are prioritizing investigations in the life sciences sector. The first article analyzed the DOJ’s handling of the case, discussing how the declination and indictment shed light on new DOJ policies. See “The Changing Landscape of the French ‘Secret Professionnel’” (Apr. 8, 2026).

Anthropic’s Mythos Model Forces Companies to Regroup for a New Cyber Era

Anthropic’s recent disclosure of an AI bug‑finding model deemed too “dangerous” for public release is forcing companies to rethink their cybersecurity programs and operations. Instead of releasing the model broadly, the company has convened a closed group of industry leaders across cloud infrastructure, operating systems, networking and finance to deploy its Claude Mythos Preview model in controlled testing of critical software. A week after Anthropic’s announcement, OpenAI likewise revealed it had provided a select group access to its own unreleased model for cyber testing and remediation. This article examines how Mythos-class models may alter expectations for cybersecurity programs and create pressure on existing vulnerability-sharing frameworks. It also outlines concrete steps GCs and boards should consider as AI compresses vulnerability discovery and exploitation timelines. See “Tool or Third Party? Courts Differ on AI’s Role in Privilege and Work-Product Protections” (Mar. 25, 2026).

The Data Analytics and AI Transition in Compliance

2025 was a year of pilot projects and experimentation with AI, while 2026 is turning out to be a year in which companies increasingly demand efficiency gains through new technologies, even in compliance. As a result, compliance functions that were once based on the memories, intuition and experiences of human beings are increasingly handed over to AI algorithms. A March 2026 Practising Law Institute panel discussion analyzed the ongoing transition of compliance programs toward prioritizing data analytics and AI, with a focus on how compliance teams can use these tools for compliance monitoring and managing third-party risk. This article summarizes the panel’s key takeaways. See “How Tech CLOs Think Attorneys Should Be Using AI” (Apr. 22, 2026).

Steptoe Welcomes Compliance and Investigations Partner in D.C.

Steptoe has announced that Shelita Stewart has joined the firm as a partner in its investigations, white‑collar defense and compliance group in Washington, D.C. She previously served as senior deputy GC at Comcast Corporation and arrives from Hogan Lovells. For commentary from Stewart, see “Entain Case Illustrates Online Gaming Growing Along With Enforcement” (Feb. 28, 2024).

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