When Compliance Becomes Dangerous, Part I: High-Risk Foreign Assignments and the Enforcement Gap

              International criminal enforcement often begins long before a prosecutor files an indictment or a regulator announces a settlement. It may begin inside a multinational enterprise, when a lawyer questions a suspicious payment, an auditor identifies irregular transactions, a compliance officer refuses to approve a deficient review, or a finance professional detects signs of corruption, forced labor, trafficking, sanctions evasion, counterfeiting, money laundering, or organized criminal influence. At that moment, corporate compliance ceases to be an internal procedure alone. It becomes part of the broader enforcement ecosystem.