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    Jun. 3, 2026

What to Know About the E.U. Anti-Corruption Directive

In April 2026, the European Council gave the final go-ahead to a new directive (Directive) that will harmonize anti-corruption laws among the E.U.’s member countries. When transposed into national laws, the Directive will provide a standard definition of corruption, a common level of penalties for such offenses, rules to strengthen investigations and prosecutions, and new specialized bodies to prevent corruption. It also will introduce a standalone offense of trading in influence, a “failure to prevent” form of corporate liability and extraterritorial reach. The Anti-Corruption Report spoke with European counsel to understand the potential implications of the Directive. See our two-part series on emerging global compliance standards: “DOJ, OECD and World Bank Guidance” (Oct. 22, 2025), and “AFA, SFO and Eight Common Compliance Elements” (Nov. 5, 2025).

Operating in Venezuela: Understanding the Context and Principal Risks

With enthusiastic encouragement from the Trump administration, companies are considering opportunities in oil, mining and other core resource sectors in Venezuela despite continuing political and compliance risks. In this first article of a two-part series, Miller & Chevalier members Matteson Ellis and James Tillen, with counsel Collman Griffin and visiting law clerk Angelo Márquez, examine why Venezuela is attractive to businesses and outline two of the principal risks companies face. The second installment will examine some additional areas of risk and present practical mitigation strategies, from pre-investment diligence to operational controls. For more from Miller & Chevalier, see “How the U.S. Focus on Cartels and Transnational Criminal Organizations Impacts Multinationals in Mexico” (Jul. 2, 2025).

The Importance of Due Diligence in Brazil as Operation Hidden Carbon Unfolds

Following the onset of the Lava Jato scandal in 2014, Brazil became a focus of anti-corruption enforcement but then activity slowed as the Brazilian political winds shifted. Now, the confluence of enforcement trends in the U.S. and Brazil has brought the country back into the spotlight, particularly with the U.S. Department of State’s announcement that it will be designating two Brazilian criminal organizations as foreign terrorist organizations. Just before that announcement, the Anti-Corruption Report sat down with Adriana Dantas, a partner at Lefosse Advogados, who will be speaking at the American Conference Institute’s 14th Summit on Anti-Corruption, Integrity and ESG in Brazil in June 2026, to discuss the current state of affairs in her country. See “The Impact on Latin America of Designating Cartels As FTOs” (Jan. 14, 2026).

How CCOs Can Make the Case for Compliance in Trump 2.0

Even though U.S. enforcers continue to assert their commitment to the FCPA, albeit with a shift in focus to match the policy goals of the second Donald Trump presidential administration (Trump 2.0), many corporate leaders have not moved past the executive order pausing enforcement from March through June 2025. At a March 2026 Practising Law Institute panel, experts discussed the changes in U.S. anti-corruption enforcement and offered guidance on how CCOs can defend compliance budgets and maintain compliance programs and culture with fewer resources. In particular, they recommend highlighting the business advantages compliance can provide, as well as how to make use of dual-hatted employees and agentic AI to drive efficiencies. This article summarizes their insights. See “Former Enforcers Offer Seven Ways to Keep Compliance Strong During the Trump Administration” (Sep. 24, 2025).

AI Agent Security: Companies See Rogue Incidents but Lag on Controls

At many organizations, AI agents are no longer experimental. While use of this autonomous technology grows, companies are relying on immature controls to rein it in. Three recent reports detail multiple types of security and privacy breaches already occurring due to organizations’ inadequate policies, limited monitoring and failure to appropriately treat AI agents as risks in their systems. This article, the first in a two-part series on real-world security for AI agents, examines the reports’ benchmarks of incident types, and the safeguards and security measures that companies so far are applying to agents. Part two will provide a playbook for chief information security officers and their colleagues to strengthen security and reduce risks around AI agents. See “From CEO Deepfakes to AI Slop, AI Incident Tracking Ramps Up” (Aug. 13, 2025).

Freshfields Adds Senior Treasury Official to White-Collar Practice

Alessio Evangelista has joined Freshfields as a partner in its white-collar defense and corporate crime practices in the firm’s Washington, D.C., and New York offices. For commentary from Evangelista, see “Robinhood Resolution a First for Cryptocurrency Enforcement in NY” (Sep. 14, 2022).

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