Corruption Crime & Compliance
Michael Volkov discusses current and hot topics in the legal realms of corruption, crime, and compliance.
Episodes
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
Episode 416 -- DOJ Indicts Chinese Shipping Container Cartel: Antitrust Compliance Lessons for Every Company
The Justice Department unsealed a historic superseding indictment charging four of the world's largest shipping container manufacturers — CIMC, Singamas, Dong Fang, and CXIC — and seven senior executives for conspiring to restrict global container output and fix prices from November 2019 through at least January 2024, covering an estimated $35 billion in commerce and generating near-hundredfold pr
Does Your Speak-Up Culture Actually Work? (Part 1)
What if the C-suite handed you a gold-plated whistle and asked you to blow it?Here's the uncomfortable truth.Most corporate scandals were discovered by employees long before management ever learned about it or acted.The problem wasn't a lack of information.It was a culture where people were afraid to speak up.Companies with strong speak-up cultures detect misconduct earlier, reduce enforcement ris
How Do You Avoid a Corporate Fine When Criminal Conduct Is Discovered? (Part 2)
Your company has uncovered a massive criminal scheme.You want to get out of it - you serve up the mastermind on a silver platter for the Justice Department prosecutors.You're working with the Justice Department and you have to deliver to them one key aspect - individuals who were responsible must be held accountable.How do you do that?You conduct a thorough internal investigation and you collect,
Episode 415 -- DOJ’s Massive $550 Million Tariff Evasion Settlement — What Every Company Needs to Know
The Department of Justice’s $549.5 million False Claims Act settlement with Perfectus Aluminum marks one of the largest customs fraud recoveries in recent years and signals an aggressive new era of tariff enforcement. In this episode, Michael Volkov examines DOJ’s expanding use of the False Claims Act to pursue alleged tariff circumvention schemes, the growing role of whistleblowers in customs enf
How Do You Avoid a Corporate Fine When Criminal Conduct Is Discovered? (Part 1)
Your company uncovers a massive criminal scheme.Are you gonna go down with the ship or are you gonna grab onto the lifeboat that the Justice Department has sent your way?The era of big corporate fines is over, and you have to make sure that you get your company through this without a big fine.What do you do?The Justice Department's corporate enforcement policy has been revised, and it makes it ver
What Are Your Third Party AI Risks? (Part 2)
So approximately 10-20% of your third parties are going to present serious AI risks. How do you mitigate those risks? Here's what you do.One, you assess your needs and identify the risk calculation for each of your third parties, and then you seek two fundamental solutions.Two, contractual provisions are critical, and there's 6 of them that you need. You have to restrict data use so that it's in a
Episode 414 -- A Conversation with Kilby Macfadden: Organizational Justice and the Future of Internal Investigations
In this episode of Corruption, Crime, and Compliance, Michael Volkov interviews Kilby Macfadden, J.D., CCEP, Managing Director and Associate General Counsel at KPMG LLP, where she serves as Head of Investigations overseeing complex ethics, compliance, and enterprise risk matters. Drawing on her extensive experience in government enforcement and corporate compliance, Kilby discusses the growing imp
Organizational Justice and DOJ Expectations — Why Internal Investigations Define Your Compliance Program
In this episode, we examine how organizational justice and effective internal investigation systems sit at the core of the U.S. Department of Justice evaluation of corporate compliance programs. Drawing on benchmarking data from NAVEX Global and research from George Washington University, we explain why strong speak-up cultures generate more internal reports, detect misconduct earlier, and reduce
What Are Your Third Party AI Risks? (Part 1)
Everyone is using AI, including your third parties. Could that land you into legal trouble? Absolutely.So what are your third party AI risks?These include the standard list, data privacy risks, lack of transparency, bias and discrimination, IP and content, and of course regulatory risks.So, what can your third party do that gets you into the hot water?Well, they could be a SAS provider who integra
New Cuba Sanctions Expansion and Compliance
In this episode, Michael Volkov analyzes the May 1 executive order signed by Donald Trump expanding U.S. sanctions targeting Cuba. The discussion highlights the order’s broad scope, including new authorities to sanction actors involved in key economic sectors, corruption, and human rights abuses, as well as its extension of secondary sanctions risk to foreign financial institutions. With increasin
Tariffs, OFAC and the DOJ (Part 2)
When it comes to trade compliance, don't let the Justice Department make an example out of you and your company.Build an effective trade compliance program. Here are the steps.Step 1, get the buy-in from leadership. That means your board of directors and your senior executives.Number 2, always do a risk assessment and update it. Look at your export and import risks, identify those that are signifi
Third-Party AI Risk and Vendor Due Diligence
In this episode of the Corruption, Crime & Compliance podcast, Michael Volkov explores the growing risks associated with third-party use of artificial intelligence and why companies must update their vendor due diligence and onboarding processes. As AI becomes embedded in SaaS platforms, analytics tools, and service providers, organizations are increasingly exposed to risks they may not fully
Tariffs, OFAC and the DOJ (Part 1)
Is your trade compliance program low hanging fruit for the Department of Justice and the regulatory agencies?The Justice Department and regulators are focused on enforcement.Civil and criminal penalties are increasing on the import side, tariffs are now a regulatory focus and also a Justice Department focus with regard to the False Claims Act.Criminal and civil penalties are coming.On the export s
Building a Best-in-Class AI Use Policy
In this episode of the Corruption, Crime & Compliance podcast, Michael Volkov examines how companies can design and implement a best-in-class AI Use Policy to manage the rapidly evolving risks associated with artificial intelligence. As organizations deploy AI tools across business functions, Volkov explains why traditional governance approaches fall short and outlines a practical framework fo
Protecting Profit Through Ethics
It's tempting to cut ethics and compliance in this time. But that would be a mistake.Ethics and compliance provide important fundamental values that in the end make a company more profitable.They promote employee well-being, employee engagement, and makes sure that employees have a vested interest in their company.This is not the time to start jeopardizing those important values.So keep the messag
FinCEN's AML Reform Proposal -- A Shift Toward Risk, Clarity and Innovation
FinCEN’s April 2026 proposed rule marks a major shift in AML/CFT compliance by redefining how programs are evaluated, enforced, and managed under the Bank Secrecy Act. In this episode, Michael Volkov breaks down the proposal’s most significant changes, including the new two-pronged framework distinguishing program design from implementation, a higher threshold for enforcement focused on systemic
What Is the ‘Ethics Premium’?
Your board thinks compliance is a cost center. Here's the research that proves them wrong and how to make sure they know it.Want help making the case for compliance at the top? Visit volkovlaw.com
Is Your AI Risk Assessment Ready? (Part 2)
Here are 3 more reasons you may think twice about letting ChatGPT run your compliance program.First, content monitoring.The content that you generate through ChatGPT or any AI service can raise real risks with regard to improper intellectual property, data privacy risks where you name certain individuals or name certain identifiers, and most importantly, remember your third-party risks.When it com
Episode 406: AI Risks and Compliance – Building a Governance Framework
Artificial intelligence is rapidly transforming business operations—but it is also introducing a new generation of legal, ethical, and compliance risks. In this episode, we explore how AI risk is accelerating across organizations, from data leakage and bias to over-reliance on flawed outputs and hidden third-party exposure. Drawing on real enforcement trends and practical examples, we explain why
Is Your AI Risk Assessment Ready? (Part 1)
Are you actually thinking of turning over your compliance program to ChatGPT? If so, you need to listen to this.AI has to be implemented in a methodical way, a step-by-step program. So let's talk about those steps.First, you need a governance structure, meaning you have to have an organization responsible across the entire organization for all your uses of AI.Second, like every issue that we deal
Episode 405 - DOJ Balt Declination: Individual Accountability in Action
In this episode, we examine the Department of Justice’s declination in the Balt Medical case—a textbook example of how DOJ is applying its Corporate Enforcement Policy in practice. Despite a multi-year foreign bribery scheme involving payments to a physician at a state-owned hospital, DOJ declined to prosecute the company based on its timely self-disclosure, full cooperation, and effective remedia
Episode 404 -- Venezuela Sanctions Update (2026)
In this episode, we break down the sweeping shift in U.S. sanctions policy toward Venezuela following the 2026 political transition and the issuance of multiple new general licenses by the Office of Foreign Assets Control. While the U.S. has opened the door to significant commercial activity—particularly in oil, gas, and minerals—this is not a full lifting of sanctions but a highly conditional fra
Episode 403 -- The Continuing Threat of FCPA Enforcement Against Individuals
The final quarter of 2025 produced a modest resurgence in Foreign Corrupt Practices Act (FCPA) activity following the administration’s June 2025 FCPA guidelines. Whether that uptick signals a sustained enforcement trend remains uncertain. But one theme remains clear: individual FCPA enforcement is alive and well.While corporate resolutions may benefit from evolving DOJ policy and a renewed em
Episode 402: Paul Allen: The Promise of AI, Governance and Public Trust
In this episode of Corruption, Crime and Compliance, Michael Volkov sits down with entrepreneur and innovator Paul Allen, founder of Ancestry.com and Soar.com, to explore the evolving intersection of artificial intelligence, governance, and public trust. Paul shares insights from his latest venture, CitizenPortal.ai, an AI-powered civic intelligence platform aimed at making government activity mor
Episode 401 -- Commerce Department's Recent Export Controls Enforcement Actions
The U.S Department of Commerce announced two settlements recently involving export control enforcement actions.First, the Department of Commerce’s Bureau of Industry and Security (BIS) imposed a $374,474 civil penalty against California-based satellite technology supplier Vizocom for unlawfully exporting controlled technical data related to military antennas to a Chinese manufacturer.Second, (BI
Episode 400: Reopening 9/11 -- A UK Supreme Court Battle Over Truth, Power, and Accountability
In this episode, I sit down with Matthew Campbell, whose decades-long effort to seek answers about the death of his brother in the World Trade Center has now reached the doorstep of the Supreme Court of the United Kingdom.This is not a case about liability for the September 11 attacks. Instead, it raises a fundamental constitutional question: can the UK government refuse to reopen an inquest—witho
Episode 399 -- Vera Cherepanova on Boards of the Future
Vera is a Chartered Accountant, Certified Internal Auditor, and award-winning Ethics and Compliance expert who writes and speaks about philosophy, business ethics, compliance, risk, and governance.She is the Executive Director of Boards of the Future™, a non-profit that works with corporate boards globally to advocate for stronger ethics, risk, and compliance backgrounds.She spends time between Mi
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