Corruption Crime & Compliance
Michael Volkov discusses current and hot topics in the legal realms of corruption, crime, and compliance.
Episodes
Episode 457 -- AML Compliance Shift to Effectiveness
In this episode of Corruption, Crime and Compliance, Michael Volkov examines FinCEN's April 2026 proposal to rebuild the Bank Secrecy Act AML program rule around an effectiveness standard, with a two-prong test requiring that programs be both established (risk-based, built on four core elements, and kept current) and maintained (implemented in all material respects), along with a new enforcement t
Are Your Export Controls Built Into the System?
If a $36 million export violation comes down to whether a loading dock worker grabbed the right box, the problem isn’t the guy on the dock.BAE Systems just paid $36 million to the State Department for more than 100 export control violations.Here’s what makes this case worth your attention.DDTC didn’t find willful evasion. It found something more common and, honestly, scarier: a well-intentioned co
Episode 456 -- Buying a Sanctions Violation
In this episode of Corruption, Crime and Compliance, Michael Volkov explains why acquiring a sanctions violation is even riskier than buying an FCPA problem: under programs like Cuba and Iran, U.S. ownership of a foreign target can itself create sanctions jurisdiction on closing day, turning previously lawful foreign business into violations overnight. Drawing on OFAC's 2019 Framework for Complian
Can a Company Survive C-Suite Misconduct?
A pharma CEO just found out the captain doesn’t always go down with the ship. Sometimes the ship stays afloat by handing him to DOJ.Veloxis Pharmaceuticals just paid over $46 million to resolve a kickback scheme involving its kidney transplant drug, lavish meals, resort stays, payments dressed up as consulting fees paid to doctors and pharmacies to drive prescription demand.Here’s the part that sh
Episode 455 -- Updating Your Sanctions Compliance Program
In this episode of Corruption, Crime and Compliance, Michael Volkov explains why OFAC's 2019 Framework for Compliance Commitments, built on the five pillars of management commitment, risk assessment, internal controls, testing and auditing, and training, remains the essential foundation for any sanctions compliance program, while also walking through the substantial multi-agency guidance that has
Is Embedded AI Slipping Past Your Controls?
Today’s version of the Trojan horse doesn’t need to sneak past your gate in the dead of night. It’s a software update to something you already let in.Second preview ahead of tomorrow’s webinar, and this one’s about a blind spot I see constantly.Most compliance officers think about shadow AI as employees going out and signing up for some random chatbot.That happens, but the bigger risk right now is
Episode 454 -- The Marriage of Compliance and Data
In this episode of Corruption, Crime and Compliance, Michael Volkov traces the decades-long relationship between compliance and data, from the profession's earliest, checkbox-style attempts to measure program effectiveness through crude proxies like hotline volume and training completion rates, through the rise of continuous monitoring systems, integrated dashboards, and key risk indicators that e
Is Your Third-Party Risk Program Ready for AI?
An AI tool isn’t a piece of software. It’s a locked door, and you have no idea how many people have a key.Quick preview ahead of tomorrow’s webinar on AI and third-party risk, because I want you thinking about this before we dive in.Here’s the mental shift every compliance officer needs to make: every AI tool your company adopts is a third-party vendor relationship, often a more complicated one th
Episode 453 -- Rounding Out Sanctions, Tariff and Trade Developments
In this episode of Corruption, Crime and Compliance, Michael Volkov rounds up three major economic policy developments happening alongside Operation Economic Outcast: the State Department's rescission of Syria's nearly 47-year State Sponsor of Terrorism designation, opening the door to renewed trade and eased export controls; an escalating tariff war with Canada following the collapse of USMCA ren
Can DOJ Make an Indictment Disappear?
For anyone hoping a friendlier DOJ can make their old charges disappear, a federal judge just reminded us that vanishing requires his or her permission.Big development out of Brooklyn federal court.DOJ tried to drop the remaining bribery and obstruction charges against executives tied to Indian billionaire Gautam Adani.The judge said no.Judge Nicholas Garaufis ruled that Deputy AG Trent McCotter’s
Episode 452 -- Operation Economic Outcast: A Significant Expansion of Iran Sanctions and Enforcement
In this episode of Corruption, Crime and Compliance, Michael Volkov devotes a full deep dive to Operation Economic Outcast, Treasury's aggressive campaign to close off Iran's remaining financial and commercial channels following the collapse of a June 2026 US-Iran memorandum of understanding. He walks through OFAC's expansion of sectoral sanctions into aviation, digital assets, gold, shipping, and
Is Your Compliance Budget Ready for 2027?
If you’re planning for 2027 with 2025’s budget in mind, your compliance program is about to fall on its face.KPMG just surveyed 725 chief compliance officers, and the headline is simple: the job has fundamentally expanded, and if your 2027 plan doesn’t reflect that, you’re already behind.75% of CCOs say cybersecurity and data privacy are top investment priorities.77% say the same about data analyt
Episode 451 -- Two Executives, Two Sentencings, One Week
In this episode of Corruption, Crime and Compliance, Michael Volkov examines two significant executive sentencings handed down within a day of each other: Tomás Niembro Concha, the former CEO of Puerto Rico's now-defunct Nodus International Bank, sentenced to more than nine years for a multiyear fraud scheme that fleeced his own bank of nearly $25 million and a scheme to evade U.S. sanctions on Ve
When Does Board Oversight Become Bad Faith? (Part 2)
Lo and behold, Boeing gets sued over another safety crisis, and this time Boeing actually won.Want to know why? They kept the receipts.Yesterday I told you about two cases where Delaware let Caremark claims move forward. Today, the case where the board won, and its most important Caremark decision in years.Boeing again. New litigation, this time over the 2024 Alaska Airlines door plug incident. Gi
Episode 450 -- Your Vendor Contract Template Was Not Built for AI
In this episode of Corruption, Crime and Compliance, Michael Volkov explains why standard software procurement templates fail to protect organizations in AI vendor relationships, and what to do about it. He walks through the structural differences that make AI vendors riskier than traditional software vendors, multi-layered data flows through underlying foundation models, frequent model swaps, and
When Does Board Oversight Become Bad Faith? (Part 1)
Hiring someone to investigate misconduct isn’t always going to save your board. The line between bad management and bad faith just got real.Here’s a question every board member should be losing sleep over: when does a board’s failure to catch corporate misconduct cross the line from bad management into an actual breach of fiduciary duty?Delaware just gave us two new answers, and they cut in differ
Episode 449 -- The EU AI Act Is No Longer Theoretical
In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down why the EU AI Act has moved from a future planning exercise to an actively enforced regulatory regime, with the European Commission's AI Office holding full investigative and fining authority since August 2026, having already opened its first formal investigations in June 2026 into hiring tools, credit scoring systems,
Can You Get Off the SDN List?
Has OFAC branded your company with the scarlet letter?Getting removed from the SDN list is possible, but it’s not fast, it’s not easy, and it’s not guaranteed.The primary path is a petition for administrative reconsideration filed with OFAC, arguing mistaken identity, changed circumstances, or that the original factual basis was simply wrong.You must prove it with real documented evidence.OFAC is
Episode 448: Caremark in 2026 — Where Delaware Draws the Line Between Bad Judgment and Bad Faith
In this episode of Corruption, Crime and Compliance, Michael Volkov examines how Delaware's Caremark doctrine has matured through a recent run of decisions involving Teligent, Regions Financial, and Boeing, all centered on the question of when a board's failure to prevent corporate misconduct crosses from ordinary mismanagement into an actual breach of the duty of loyalty. He walks through Teligen
Is Your Sanctions Screening Enough?
Are you rubbing elbows with criminals?When OFAC designates someone a specially designated national, or SDN, it’s not a warning label. It’s a legal wall.Every asset that party has anywhere in U.S. jurisdiction, or in the hands of a U.S. person, is frozen. Every U.S. person is barred from transacting with them, directly or indirectly.The trap is OFAC’s 50% rule, which means any entity owned 50% or m
Episode 447 -- Veloxis Pharmaceuticals' $46 Million Kickback Settlement and What the CEP Really Rewards
In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down Veloxis Pharmaceuticals' more than $46 million settlement with DOJ and HHS-OIG over a years-long kickback scheme involving its kidney transplant drug Envarsus XR, a scheme the DPA says was directed in part by the company's own former CEO. He examines why Veloxis avoided prosecution and instead secured a deferred prosec
When You Fail to Fix an Already Flagged Compliance Gap
At $125 million, breaking the law can never be a cost of doing business.UBS Bank was hit with a $125 million FinCEN penalty, the largest ever against a broker-dealer under the Bank Secrecy Act.This is UBS’s second Bank Secrecy Act action in less than a decade. In 2018, regulators told UBS: fix your foreign currency wire monitoring. It never did.The same gap stayed open for years, letting more than
Episode 446 -- L3Harris's CEO Ouster and the Board Governance Lesson Nobody Learns the First Time
In this episode of Corruption, Crime and Compliance, Michael Volkov examines L3Harris Technologies' abrupt ouster of chairman and CEO Christopher Kubasik over a code-of-conduct violation, and why the story is really a board governance cautionary tale rather than a typical enforcement matter. He traces Kubasik's earlier, similar departure from Lockheed Martin in 2012 alongside comparable cases invo
Could Your Routine Customs Payment Actually Be a Bribe?
Is your routine payment actually a bribe?Scolar, an Omaha agricultural company, resolved an FCPA case for over $10 million after using customs brokers to bribe Mexican officials, about $2,000 for each train that crossed the border. It was invoiced as reinspection fees paid routinely for six years.Nobody asked what the money actually bought.Stop treating customs brokers, freight forwarders, and log
Episode 445 -- Why Your Organization Needs an AI Acceptable Use Policy
In this episode of Corruption, Crime and Compliance, Michael Volkov makes the case that every organization needs a written AI Acceptable Use Policy now, not eventually, because employees are already using AI tools with or without formal governance. He walks through the three core risk categories driving that urgency: confidentiality exposure when employees submit sensitive data to ungoverned tools
Can Your Biggest FCPA Risk Be a Trusted Insider?
Have you heard about the Goldman Sachs banker who bribed his way to a conviction?A federal jury in Brooklyn last week convicted Asante Berko, a former Goldman Sachs executive, on FCPA conspiracy, a substantive FCPA violation, and money laundering conspiracy.Berko managed a deal between a Turkish energy company and the government of Ghana to build a new power plant in Ghana. To win the bid, he and
Is Trade Fraud the Next Major False Claims Act Risk?
If you think your company can smuggle and fly under the radar screen, think again.When your company touches imports, customs, or tariffs, you need to know this.The Justice Department stood up a dedicated trade fraud task force in August of last year. Its first settlement came three months later.This past May, it delivered the largest customs-related False Claims Act recovery ever: $550 million fro
Episode 444 -- BAE Systems' $36 Million ITAR Wake-Up Call
In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down the State Department's $36 million settlement with BAE Systems, Inc. over more than 100 alleged violations of the International Traffic in Arms Regulations and Arms Export Control Act spanning 2019 through March 2025, including unlicensed technical data exports to China, Canada, the U.K., and Germany, unauthorized defe
Where Is DOJ Taking False Claims Act Enforcement Next?
You think you can cheat the government? The False Claims Act says you’ll pay for it three times.The 2026 False Claims Act mid-year numbers are out, and the story is clear. DOJ isn’t backing down. It’s leaning in.DOJ is using the FCA (False Claims Act) to drive administration policy priorities. In the first half of this year alone, it notched first-ever settlements in four distinct areas: gender-re
Episode 443 -- Nothing Crosses the Border for Free
In this episode of Corruption, Crime and Compliance, Michael Volkov examines the compliance risks lurking in ordinary U.S.-Mexico cross-border trade, explaining how the plaza system allows cartels to function as a de facto taxing authority over certain border corridors, extracting piso payments from legitimate commercial shipments that pass through their territory, often through customs brokers an
Could AI Use Waive Privilege in Your Internal Investigation?
When using AI in your internal investigation, make sure you protect the attorney-client privilege.A lot of investigators are feeding interview notes, documents, even witness statements into AI tools to help organize an investigation.That’s convenient, for sure, but ask yourself: where does that data go? Is that platform actually covered by your privilege log? Did outside counsel direct that use, o
Episode 442 -- When Forced Labor Risk Hits the P&L
In this episode of Corruption, Crime and Compliance, Michael Volkov explains why forced labor compliance has shifted from a sustainability afterthought into a direct financial and operational threat. He walks through the U.S. Trade Representative's new two-tier Section 301 tariff structure targeting 60 trading partner economies over forced labor practices, the rebuttable presumption under the Uygh
Can You Trust AI During an Internal Investigation?
When you’re conducting an internal investigation and using AI as a tool, you’re risking the use of a shifty informant.Let’s talk about a risk that I’m seeing firsthand in internal investigations: AI hallucination.I use AI in my own practice, and I got scared very quickly because it cited cases that don’t exist. It cited them confidently, persuasively, like it was reading straight off a court docke
Episode 441 -- Severin Wirz on his New Book, "Bribery Beyond Borders: A History of the FCPA"
On the Corruption, Crime and Compliance podcast, host Mike interviews Severin Wirtz, an in-house compliance lawyer (now at a semiconductor company, formerly at Trace International and a law firm where he cut his teeth on the Bonny Island FCPA case) about his new book, Bribery Beyond Borders, a history of the Foreign Corrupt Practices Act that took him nearly fifteen years to research and write. Wi
Are You Looking for DOJ Enforcement in the Wrong Place?
If you’re looking at the Justice Department and only at FCPA cases, you’re looking in the wrong place.Everyone’s talking about the DOJ going soft on corporate crime. I want to push back on that narrative because I think it’s incomplete and, honestly, a little dangerous if compliance officers believe it.Yes, traditional FCPA and bribery prosecutions have slowed. But look at where the resources are
Episode 440-- Chris Focacci: AI, Due Diligence, and the Limits of Machine Judgment
In this episode of Corruption, Crime and Compliance, Michael Volkov sits down with Christian Focacci, founder of Threat Digital, for their annual check-in on AI's evolving role in due diligence and compliance. Focacci traces how AI adoption has matured from early hype and generic chatbot rollouts to more disciplined, use-case-specific tooling, while cautioning that the underlying models still hall
Has DOJ Enforcement Shifted Rather Than Slowed Down?
Everyone’s talking about the DOJ going soft on crime.I want to push back on that narrative because I think it’s incomplete and, honestly, a little dangerous if compliance officers believe it.Yes, traditional FCPA and bribery prosecutions have slowed, but look at where the resources actually went. Trade enforcement is exploding. Sanctions enforcement is aggressive and getting more aggressive by the
Episode 439 -- The Scoular Company FCPA Resolution
In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down the Justice Department's $10.2 million foreign bribery resolution with The Scoular Company, an Omaha-based agricultural supply chain company that used customs brokers to pay more than $400,000 in bribes to Mexican officials over six years so that contaminated grain shipments could cross the U.S.-Mexico border despite f
Should Compliance Programs Relax When DOJ Enforcement Slows Down?
When it comes to DOJ enforcement, the pendulum swings, and it always returns. Don’t let it knock you off your feet.I’ve been watching the headlines, and so have you. Fewer corporate guilty pleas, non-prosecution agreements for Alibaba and Eagle Bank, charges dropped against Boeing and Halkbank from Turkey.The word from Main Justice is: hold individuals accountable, go easier on companies. I get wh
Episode 438 -- The Fight to Save the Corporate Transparency Act: An Urgent Update
In this update episode of Corruption, Crime and Compliance, Michael Volkov speaks with Erica Hanichak of the FACT Coalition and Frank Russo of Modern Fortis about the current fight over the Corporate Transparency Act, the 2021 law requiring companies to report their beneficial owners to a secure Treasury Department database in order to close off the U.S.'s longstanding status as an easy jurisdicti
Is Your Compliance Program Losing Its Seat at the Table?
Is your compliance program being demoted?Let’s talk about something that should worry every compliance officer. The stature of the profession is slipping.For years, the trend line was clear. Compliance officers moved out from under the general counsel, got direct lines of reporting to the CEO, and direct lines to the board.That mattered. It wasn’t just symbolic. It meant compliance had real influe
Episode 437 -- Where Your CCO Reports Tells Me Everything: The Quiet Backslide in Compliance Reporting
Michael Volkov examines a troubling backslide in corporate governance: the quiet movement of chief compliance officers back under the general counsel after years of progress toward direct CEO reporting lines. Michael explains why the CCO's reporting structure is the single clearest signal a company sends about the value it places on compliance — shaping whether compliance influences business strat
Is a Quiet Compliance Hotline Really Good News?
In the compliance world, no news is not good news.Let me ask you a question every CCO should be asking right now: Are your employees actually reporting and using your hotline to report legitimate concerns?Too many compliance officers look at a quiet hotline and breathe a sigh of relief. No calls, no complaints. Must mean everything’s fine.I’m here to tell you that’s backward. A silent speak-up lin
Episode 436 -- Internal Investigations and AI
Michael Volkov examines how artificial intelligence is transforming internal investigations — and what the Justice Department now expects from companies navigating this new landscape. Michael breaks down DOJ's updated Evaluation of Corporate Compliance Programs, which directs prosecutors to scrutinize how companies assess AI risks, whether compliance functions have adequate access to data and anal
What Is the Ethics Premium?
The root of every strong compliance program is a strong culture.I say this on every episode, and I’m going to keep saying it. Culture is the single most important control that your compliance program builds. It’s at the heart of every compliance program—not the policy binder, not the training module. Culture.Here’s what the research really shows: companies with strong ethical cultures perform bett
Episode 435 -- Inside the Mind of the CCO: Aaron Nicodemus on Compliance Trends, AI Governance, and Reporting Lines
In this episode of Corruption, Crime and Compliance, Michael Volkov talks with Aaron Nicodemus, editor-in-chief of Compliance Week, about the state of the compliance profession and the findings of Compliance Week's latest "Inside the Mind of the CCO" survey. They discuss a troubling reversal in reporting lines, with more compliance officers now reporting through general counsel rather than directl
Which Vendors Create the Most Risk?
Some third parties create real legal risks.Other third parties create reputational risk.Not all third parties are the same.One of the most important concepts in modern third-party risk management is distinguishing between acting vendors and incidental vendors.An acting vendor performs services on your behalf.Think customer service providers, recruiters, customs brokers, distributors, and payment p
Episode 434 -- Due Diligence in the Age of AI: A Conversation with Dan Greenberg
In this episode of Corruption, Crime and Compliance, Michael Volkov sits down with Dan Greenberg, founder of Greenberg Corporate Intelligence, to unpack how due diligence and corporate investigations have evolved over Dan's fifteen-plus years in the field. They cover the uneven state of corporate transparency worldwide, from the UK's Companies House registry to persistent secrecy havens in the BVI
Foreign Bribery Has No Borders
When it comes to foreign bribery, borders provide no protection.The European Union just approved one of the most significant anti-corruption initiatives in decades, and multinational companies have to pay attention.The EU's Anti-Corruption Directive is designed to harmonize anti-corruption enforcement across the member states.It expands corruption offenses, strengthens enforcement tools, and incre
How Many Red Flags Are You Missing?
How many red flags is your company missing?We've seen this pattern repeatedly.A third-party red flag appears.No one knows who owns the escalation process.Business pressure overrides compliance concerns.Documentation is incomplete. Monitoring never occurs.When the regulators arrive, the company can't demonstrate effective oversight.The problem is not simply the underlying misconduct.The problem is
Episode 433 -- The Corruption Reckoning: How Government Corruption Destroys Economies, Democracies, and Societies
Government corruption is often viewed as a political problem, but its consequences extend far beyond government institutions. Corruption distorts economies, undermines democratic legitimacy, destroys public trust, and weakens the social fabric upon which civil society depends. In this episode, Michael Volkov explores the full impact of corruption across economic, political, and social dimensions a
Regulators Want Proof It Works
If your third-party risk management program uses annual questionnaires and spreadsheets, your program is already obsolete.The third-party risk environment has fundamentally changed.It used to focus on financial stability, insurance, and basic due diligence.Today, your vendors create exposures to AI risks, cybersecurity threats, sanctions violations, privacy failures, supply chain disruptions, and
Episode 432 -- OFAC and OFSI Send a Clear Message: Global Sanctions Compliance Has Entered a New Era
The U.S. Treasury Department's Office of Foreign Assets Control (OFAC) and the UK's Office of Financial Sanctions Implementation (OFSI) recently issued joint guidance comparing their respective sanctions regimes. While the document provides a useful overview of similarities and differences, it also sends a much broader message: international sanctions enforcement is becoming increasingly coordinat
Your Vendors Have Vendors
Many companies carefully review each and every vendor.Almost none review their vendor's vendor.This creates one of the biggest blind spots in modern risk management.Your payroll vendor may use a third-party AI provider.Your software company may rely on multiple subcontractors.Your logistics provider may depend on dozens of suppliers across the globe.Every one of these relationships creates additio
Episode 431 -- Bosch Pays $43 Million for Illegal Huawei Exports
Bosch agreed to pay more than $43 million in penalties and disgorgement for illegally exporting products and software to Huawei in violation of U.S. export control laws, while simultaneously receiving the first declination issued under DOJ's revised National Security Division Corporate Enforcement Policy. In this episode, Michael Volkov examines the enforcement action, the compliance failures that
Who Owns Third-Party AI Risk?
When it comes to third-party vendors, what you don't know is hurting you.Third parties rely on AI for customer service, recruiting, compliance screening, marketing, and decision making.But when a third party uses AI, your organization is on the hook for legal, regulatory, contractual, and reputational risks.Organizations need to understand which third parties use AI, what tools they use, what data
Episode 430 -- OFAC's Iran General License X: A Temporary License or a Fundamental Shift?
This episode examines OFAC’s new Iran General License X and why it may represent one of the most significant Iran sanctions developments in years. Michael Volkov explains what the license authorizes, why it matters amid ongoing diplomatic negotiations, and why companies should not mistake temporary sanctions relief for a permanent policy shift. The episode highlights practical compliance steps, in
5 Keys to Effective Trade Compliance (Part 2)
Not all sanctions violations are willful.Some companies just don't know any better.An effective trade compliance program needs three critical elements.First, in addition to the two we spoke about in the last episode, organizations and companies have to monitor transactions, shipping documents, vessels, payment flows, and escalation of red flags.Employee training is critical.OFAC's compliance frame
Episode 429 -- AI Governance Collision: Why Business and Compliance Must Stop Fighting and Start Building
Artificial intelligence has created one of the most significant governance challenges organizations have faced in decades. Business leaders are under intense pressure to deploy AI quickly, while legal and compliance teams are warning about mounting regulatory, legal, operational, and reputational risks. In this episode, Michael Volkov explains why both sides are right, identifies the most dangerou
Episode 428 -- Michael Volkov Guest Appearance on Collin McKee's Podcast EndeavorsAI
Most companies think they have a handle on AI. Most don't.Compliance attorney Michael Volkov has sat across the table from Fortune 500 compliance teams, major law firms, and Berkshire Hathaway subsidiaries — and what he keeps finding is "shadow AI": people using AI at work that leadership has no idea about. In this conversation with host Collin McKee, he breaks down where the real legal risk lives
Episode 427 -- Venezuela Sanctions Update: Building the Operational Compliance Program
Michael Volkov delivers the operational compliance program guidance companies must implement to execute safely within OFAC's new Venezuela general license framework, structured around five program pillars: transaction scoping with mandatory lifecycle revalidation at each critical deal stage; beneficial ownership-based counterparty due diligence that goes beyond standard SDN screening to identify R
5 Keys to Effective Trade Compliance (Part 1)
What separates effective trade compliance programs from ineffective ones?It starts at the top.Good, bad, or ugly, it all trickles down from the top.Here are the five keys to an effective trade compliance program.The first two are building blocks for leadership and due diligence.First, senior executives and boards must actively support trade compliance.Without leadership engagement, compliance prog
AI Is Here. Is Governance?
Are your employees whispering corporate secrets into the greedy ears of public-facing AI?Many organizations have no visibility into how their employees are using AI.The solution is not to ban AI.The solution is AI governance.Organizations need approved AI tools, acceptable use policies, employee training, and ongoing monitoring.The question is no longer whether your employees are using AI.The ques
Episode 426 -- Venezuela Sanctions Update: OFAC's New General Licenses and the FGDF Framework (Part 1)
Michael Volkov examines OFAC's new Venezuela general license framework—including General License 52, General License 46B, and the newly effective General License 51B covering Venezuelan-origin minerals—analyzing how these authorizations create conditional pathways for otherwise-prohibited energy and minerals transactions while preserving the underlying blocking regime applicable to PdVSA and the G
Would You Fire AI?
If AI were a real employee and made mistakes, would you fire it?AI is transforming business operations, but organizations often overlook one fundamental problem.They hallucinate.AI can generate fake information, fake legal citations, inaccurate regulatory interpretations, incorrect sanctions screening results, and fabricated facts.The danger is not that AI makes mistakes.The danger is that it make
Episode 425 -- USTR's Section 301 Forced Labor Tariffs: A Bold Gambit with Major Compliance Implications
Michael Volkov examines USTR's unprecedented Section 301 forced labor tariff proposal, analyzing how the Trump Administration is leveraging a decades-old trade statute to rebuild broad tariff coverage following the Supreme Court's invalidation of IEEPA emergency tariffs in Learning Resources, Inc. v. Trump. Covering economies that account for an estimated 99.4% of U.S. imports, the proposal would
Episode 424 -- When the Government Pulls the Plug: Export Controls, Anthropic, and the AI Governance Crisis
Michael Volkov analyzes the Commerce Department Bureau of Industry and Security's June 12, 2026 export control directive ordering Anthropic to suspend all access to its Fable 5 and Mythos 5 AI models for any foreign national—a directive that, because Anthropic cannot segment its global user base by nationality in real time, resulted in a complete worldwide shutoff of both models for every customer
Are You Selling Compliance Wrong to Your Leadership Team?
Compliance isn't a cost, it's a business advantage.Compliance officers often make one critical mistake, they sell compliance as a legal requirement instead of a business advantage.Executive support grows when compliance leaders connect ethics to operational resilience, revenue protection, and enhancement, reputation, employee retention, and strategic growth.Successful compliance leaders use data,
Episode 423 -- Detangling Third-Part Legal and Reputation Risks
As artificial intelligence becomes embedded in third-party business operations, companies face a new and largely unexamined compliance challenge: when does a vendor's use of AI become your legal or reputational problem? In this episode, Michael Volkov unpacks the critical agency principle distinction at the heart of third-party AI risk — explaining how acting third parties who deploy AI on a compa
What Compliance Functions Should You Automate First?
If you want to give your compliance team superpowers, then give them the power of automation.If your compliance program is still operating primarily through spreadsheets, emails, and manual tracking, regulators already view your program as ineffective.Modern compliance risks move too fast for manual systems.You need to have sanction screening, third-party monitoring, transaction testing, hotline a
Episode 422 -- Adani OFAC Settlement and Red Flag Lessons Learned
On May 18, 2026, the U.S. Treasury's Office of Foreign Assets Control (OFAC) announced that Adani Enterprises Limited (AEL), an India-based multinational, agreed to pay $275 million to settle 32 apparent violations of Iran-related sanctions — specifically for causing U.S. financial institutions to process approximately $192 million in payments for liquified petroleum gas (LPG) that originated from
How Do Undisclosed Relationships Turn Into Major Corruption Cases?
The biggest cases of corruption and fraud often have their roots in the soil of conflicts of interest.Many major corruption cases begin with something companies initially dismiss as just a conflicts issue.Conflicts of interest though are early warning signs for fraud, bribery, procurement manipulation, favoritism, and self-dealing.Weak disclosure systems allow undisclosed relationships, hidden own
Episode 421 -- The Dangers of AI Inaccuracy
Artificial intelligence tools remind us every day that they can make mistakes — but in the rush to embrace AI's extraordinary capabilities, the professional and compliance communities are not taking that warning seriously enough. In this episode, Michael Volkov draws on his own extensive experience in compliance, white-collar defense, and corporate governance to examine the real and serious danger
Are Your Distributors Getting You Into Sanctions Trouble?
Are you ready to navigate the risky waters of third-party pirates?Most sanctions violations do not happen because companies intentionally want to evade and violate sanctions. They happen because companies trust the wrong third party.The epsilon and elf enforcement matters, which I frequently speak about, demonstrate that companies get in trouble when they have weak distributor oversight, poor inte
Episode 420 -- DOJ Announces New West Coast Health Care Fraud Strike Force
The Department of Justice has announced a new West Coast Health Care Fraud Strike Force, signaling an expansion of federal enforcement efforts targeting health care fraud, telemedicine schemes, kickback arrangements, and technology-enabled billing misconduct. In this episode, Michael Volkov examines DOJ’s evolving enforcement strategy, including the growing use of data analytics and AI-driven inve
Episode 419: Polymarket Insider Trading Charges Illustrate DOJ and CFTC Prediction Markets Enforcement Strategy
Recent insider trading charges connected to Polymarket highlight the Department of Justice and Commodity Futures Trading Commission’s evolving enforcement strategy toward prediction markets and digital trading platforms. In this episode, Michael Volkov analyzes how regulators are applying traditional insider trading, fraud, and market manipulation theories to emerging event-based trading ecosystem
Episode 418: European Union Gives Final Approval to Landmark Anti-Corruption Directive
The European Union has formally approved its landmark Anti-Corruption Directive, creating the first comprehensive EU-wide anti-corruption framework. In this episode, Michael Volkov examines the Directive’s major provisions, including harmonized corruption offenses, expanded corporate liability, turnover-based penalties, whistleblower protections, and increased compliance expectations for multinati
Can U.S. Companies Do Business in Venezuela Again?
Venezuela is a tempting new business arena.Many companies assume that Venezuela remained completely off limits. That is no longer accurate, the compliance risks are actually increasing.OFAC has issued new Venezuela related general licenses in 2026 involving oil and gas, petrochemicals, mining, critical minerals, financial services, and contingent investment negotiations.US companies are cautiously
Episode 417 -- OFAC’s $275 Million Adani Settlement: The New Era of Sanctions Enforcement
In this episode of Volkov Law TV, Michael Volkov examines OFAC’s massive $275 million settlement with Adani Enterprises Limited arising from alleged imports of Iranian-origin LPG disguised as Omani and Iraqi product. The episode explores OFAC’s aggressive focus on maritime sanctions evasion, the risks created by U.S. dollar clearing transactions, the growing importance of intelligence-driven sanct
Does Your Speak-Up Culture Actually Work? (Part 2)
What if you worked at a company where whistleblowers were rewarded?An internal investigation is often the result of a whistleblower concern.And this is the most important test of a company's ethics and compliance program because employees watch exactly how leadership responds when misconduct surfaces.Poor internal investigations destroy trust through delays, inconsistent discipline, retaliation, a
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