Corruption Crime & Compliance Episode 398 -- Anik Shah, SanDisk Head of Compliance: Anti-Corruption Developments and Managing Risks
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Mar 16, 2026 Anik Shah, Director and Senior Legal Counsel for Anti-Bribery and Anti-Corruption at SanDisk with 15+ years in enforcement and compliance. He recalls SEC and DOJ investigative work. He discusses FCPA enforcement trends, why companies keep strong programs for reputational reasons, DOJ focus on individuals and self-reporting, and how AI, trade and sanctions reshape compliance risk.
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SEC Career Shaped by Crisis And FCPA Work
- Anik recalled his 15 years at the SEC starting after law school in 2008 which was a trial-by-fire experience.
- He handled CDOs, structured securities, FCPA matters and later digital assets before leaving in 2022, shaping his enforcement perspective.
FCPA Enforcement Has Shifted But Risk Persists
- Anik observed FCPA enforcement has cooled under the current administration but anti-corruption remains important.
- He cited policy shifts like the Pam Bondi memo and an executive order pause that altered enforcement priorities temporarily.
Global Rules And Reputation Keep Compliance Strong
- Anik and Michael agreed companies are not relaxing compliance despite lower US enforcement because other jurisdictions and reputational risk matter.
- He highlighted five-year statutes of limitations and investor expectations as continuing drivers of compliance.