THE WEEKLY BRIEF

Thursday, March 19, 2026

Welcome to your look at what CCI is covering this week:

Inside the New DOJ Corporate Enforcement Policy

Blanket application across sections and, apparently, at US attorneys offices. A rollback on near-miss fine reductions. And new language that may shorten the clock on internal investigations in surprising ways.

CCI unpacks what’s new about the recently published corporate enforcement policy at the Department of Justice with the help of former DOJ officials-turned-white-collar attorneys Laura Perkins, Keith Rosen, Scott Hulsey and Eric Beste.

Will the government’s latest batch of carrots and sticks be enough for companies to self-report misconduct? Experts say: Remember the policy is a guide, not a guarantee — and the window of opportunity may be narrower than companies think.

LEGAL, RISK & REGULATION

Sanctions risk is expanding everywhere all at once: Iran, Venezuela, Russia — even Florida. 

• The State of OFAC Sanctions Enforcement in 2025-26 by Jessica Carey, Roberto Gonzalez, Nicole Succar & Sam Kleiner, Paul, Weiss

• On Venezuelan Investment — Opportunity or Siren Song? by Matteson Ellis & Collmann Griffin, Miller & Chevalier

Are Your Anonymous Reporting Channels Hiding a Bigger Problem?

An allegation against a trusted work colleague reveals a downside of anonymous reporting channels — how can you be sure it is not just gossip?
By Vera Cherepanova, CCI columnist

COMPLIANCE PROGRAM BEST PRACTICES

Perspectives across consumer products, financial services and technology:

• EU Data Act: Time for a Reality Check by Zach Judge-Raza & Jamie Elbert, ZwillGen

• Banks Are Joining the Race to Issue Stablecoins; Can Their Compliance Teams Keep Up With the Risks? by David Soiles & Manish Chopra, Capgemini
• Warranty Language Might Be Your Biggest Right-to-Repair Liability by Robin S. Crauthers, McCarter & English 

IN THE LOOP: AI & COMPLIANCE

• Managing the AI Content Explosion in Financial Services by Jamie Hoyle, MirrorWeb

   

COMING NEXT WEEK

A new enforcement manual. The outgoing enforcement chief's ever-so-brief tenure. Making quarterly earnings reporting optional. What the heck is happening at the SEC? We'll try to connect the dots. (Got a tip about any of this? Email us.)

Sponsored

DOJ priorities for FCPA enforcement are shifting. A new whitepaper from Ground Truth Intelligence explains what the post-pause strategy means for compliance teams.

What you’ll learn

• Why DOJ is focusing on corruption tied to cartels and national security

• The new urgency around third-party risk in high-risk regions

• How AI and OSINT expose shell companies and payment trails

• Why early detection and self-reporting still matter most

• Watch On-Demand Webinars

• Download Resources

• Visit CCI Press
• Join the Book Club

• Listen to Podcasts

• Review Upcoming Events

• Become a Contributor

• Advertise with CCI