Innovation touches every part of the modern enterprise, and compliance professionals must be prepared not only to respond to change but to lead through it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators on the award-winning Innovation in Compliance podcast. In this episode, host Tom Fox welcomes Anik Shah, Global Director of Anti-Bribery and Anti-Corruption Compliance at Sandisk, for an insightful discussion on the pivotal shifts in FCPA enforcement during 2025 and what they signal for 2026.

Shah outlines his extensive professional background, including his prior roles at the SEC and DOJ. The conversation explores key developments from 2025, including the Executive Order pausing certain FCPA investigations, the Blanche Memo’s four criteria for opening FCPA cases, and the implications of revisions to the Corporate Enforcement Policy. He also analyzes the Communications Cellular enforcement action to highlight practical compliance lessons, focusing on strengthening AML controls, managing third-party risk, and deploying proactive compliance measures amid renewed anti-corruption scrutiny.

The episode concludes with a forward-looking discussion of emerging anti-corruption risks associated with advanced AI technologies, large AI construction projects, and related permitting activities, both in the United States and globally. Shah offers strategic recommendations for compliance professionals seeking to anticipate and manage these evolving risks.

Key highlights:

• 2025 as a Pivotal Year in FCPA Enforcement

• The Blanche Memo and Corporate Enforcement Policy Revisions

• Anti-Money Laundering and Third-Party Risk Management

• Large AI Construction Projects and Permitting Risks

• Global Anti-Corruption Laws and Compliance

• Key Takeaways for 2026

Resources:

Anik Shah on LinkedIn

Sandisk

Innovation in Compliance was recently honored as the Number 4 podcast in Risk Management by 1,000,000 Podcasts.