Compliance into the Weeds

Matt’s Key Compliance Issues and Trends to Watch in 2026

Jan 7, 2026
Anticipated FCPA enforcement against telecom giant ZTE raises questions about the impact of political influence on corporate prosecutions. They discuss the controversial indictment of SmartMatic and the risks of self-disclosure in a politicized Department of Justice. Additionally, there's concern over potential changes to Qui Tam lawsuits under the False Claims Act and ongoing conflicts between federal and state AI regulations. The financial landscape for AI funding deals is also examined, with fears of a crisis reminiscent of 2008.
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INSIGHT

ZTE Will Test FCPA Priorities

  • ZTE's pending FCPA case will be a major 2026 enforcement test and may reveal DOJ priorities.
  • Watch whether enforcement targets foreign firms only or includes U.S. companies as promised by DOJ.
ANECDOTE

Monitorship History Raises Questions

  • ZTE already had dual monitors and prior export-control penalties, raising questions on timing and overlap.
  • Tom Fox wonders whether misconduct occurred pre-2017 or during monitorships and whether monitors will be extended.
INSIGHT

Smartmatic Case Suggests Political Risk

  • Smartmatic's corporate FCPA indictment is unusual and may signal politicized prosecutions.
  • If tied to litigation with Fox News, outcomes could erode trust in DOJ impartiality.
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