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    Oct. 22, 2025

Zaglin Conviction Offers Insights on Individual Prosecutions in Trump 2.0

A federal jury’s recent guilty verdict confirms that FCPA prosecutions will persist in the second Donald Trump presidential administration. After a trial in the Southern District of Florida, Carl Zaglin, CEO of Georgia-based uniform supplier Atlanco, was convicted in September 2025 of conspiracy to commit money laundering for bribing Honduran officials to secure police supply contracts. This article analyzes the role that cooperating witnesses and international law enforcement played in the conviction and offers lessons for compliance teams, including how to identify code words for corruption using both human and artificial intelligence. See our two-part series “The FCPA Lives”: Targeting the TCO Ecosystem (Jul. 30, 2025), and Protecting American Interests (Aug. 13, 2025).

Emerging Global Compliance Standards: DOJ, OECD and World Bank Guidance

For many years, multinational companies have looked to U.S. enforcers for guidance on building their compliance programs. However, with enforcers in other jurisdictions more clearly expressing compliance expectations and the recent shift in U.S. enforcement, many companies are unsure about what guidance to follow. Speakers at the SCCE’s  24th Annual Compliance & Ethics Institute highlighted multiple sources of guidance companies can turn to for benchmarking their programs. This first article in a two-part series distilling and expanding on the speakers’ insights examines guidance from the DOJ, OECD and World Bank. The second article will explore guidance from the Agence Française Anticorruption and enforcers in the U.K., and review eight common compliance program elements. See “2024 in Review: International Cooperation Continues to Drive ABAC Enforcement” (Dec. 18, 2024).

Managing Data Transfers After Latombe

The E.U.-U.S. Data Privacy Framework (DPF) lives. Last month, the European General Court (EGC) dismissed a challenge brought by French Member of Parliament Philippe Latombe to annul the DPF – the mechanism that allows for the lawful transfer of personal data from the E.U. to certified organizations within the U.S. – and confirmed the framework’s validity. This article provides an overview of the factual and legal context underlying the EGC’s decision, the key rulings and practical considerations around data transfer practices. In addition, since the decision is far from likely to be the last word on the adequacy of the DPF, this article discusses certain future challenges that may be brought. See “Navigating Recent Changes to China’s Data Privacy Laws in Internal Investigations” (Jun. 5, 2024).

Insights From Whistleblowers on How to Foster a Speak‑Up Culture

With enforcers all over the globe offering incentives for employees to blow the whistle on corporate malfeasance, many companies are realizing the value of having employees raise concerns internally first. However, it is challenging to foster a culture where staff feel comfortable bringing issues to their supervisors or the compliance department. A recent Ethicsverse discussion featured three high-profile former whistleblowers who shared their stories to help companies understand the ways in which company culture can get in the way of speaking up and offered six suggestions on how organizations can encourage internal reporting. This article distills their insights. See “How a Whistleblower Can Derail a DPA” (Oct. 8, 2025).

Risk and Compliance Survey Highlights the Role of Compliance in AI Governance

Compliance programs continue to mature, with teams’ responsibilities expanding to encompass artificial intelligence governance and other topics as enforcement priorities shift, according to a recent survey. Each year, NAVEX, in cooperation with The Harris Poll, conducts a benchmarking study of the state of risk and compliance programs and this year received responses from 1,000 participants. This article synthesizes their findings and the insights offered during a related webinar hosted by NAVEX. See “NAVEX Shares Benchmarking Data in 2023 State of Risk and Compliance Report” (Jul. 19, 2023).

Seward & Kissel Strengthens Litigation and Investigations Group

Seward & Kissel has welcomed Mark Garibyan as a partner in its litigation and investigations group in New York. He arrives from McDermott Will & Schulte. For insights from Seward & Kissel, see “Lessons From the SEC’s Denial of Motions to Amend Off‑Channel Communications Orders” (Sep. 24, 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.