Corruption Crime & Compliance

What Is the Ethics Premium? Jul 23, 2026 1:44 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 Jul 21, 2026 35:57 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? Jul 21, 2026 1:17 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 Jul 19, 2026 33:09 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 Jul 16, 2026 1:10 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? Jul 14, 2026 1:00 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 Jul 12, 2026 7:29 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 Jul 9, 2026 1:20 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 Jul 8, 2026 6:10 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 Jul 7, 2026 1:06 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 Jul 5, 2026 7:36 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? Jul 2, 2026 1:05 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? Jun 30, 2026 8:17 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) Jun 30, 2026 1:14 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 Jun 29, 2026 8:12 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 Jun 27, 2026 28:25 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 Jun 27, 2026 9:59 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) Jun 25, 2026 1:21 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? Jun 23, 2026 1:01 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) Jun 22, 2026 11:32 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? Jun 18, 2026 1:20 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 Jun 17, 2026 8:18 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 Jun 13, 2026 9:30 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? Jun 11, 2026 1:19 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 Jun 10, 2026 8:15 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? Jun 9, 2026 1:20 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 Jun 6, 2026 10:32 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? Jun 4, 2026 1:15 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 Jun 3, 2026 10:12 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? Jun 2, 2026 1:31 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 Jun 1, 2026 6:13 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 May 29, 2026 6:30 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 May 29, 2026 5:34 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? May 28, 2026 1:27 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 May 26, 2026 5:08 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) May 26, 2026 1:14 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 May 24, 2026 11:09 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) May 21, 2026 1:26 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) May 19, 2026 1:20 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 May 16, 2026 6:13 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) May 14, 2026 1:26 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) May 12, 2026 1:21 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 May 11, 2026 44:41 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 May 10, 2026 6:07 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) May 7, 2026 1:31 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 May 5, 2026 8:45 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) May 5, 2026 1:28 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 May 4, 2026 8:28 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) Apr 30, 2026 1:22 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 Apr 29, 2026 6:29 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 Apr 28, 2026 57 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 Apr 26, 2026 10:47 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’? Apr 23, 2026 1:01 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) Apr 21, 2026 1:21 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 Apr 19, 2026 11:54 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) Apr 16, 2026 1:31 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 Apr 13, 2026 10:22 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) Apr 12, 2026 10:05 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 Apr 6, 2026 10:33 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 Mar 29, 2026 54:10 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 Mar 25, 2026 14:24 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 Mar 23, 2026 1:00:14 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 Mar 18, 2026 35:31 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

Episode 398 -- Anik Shah, SanDisk Head of Compliance: Anti-Corruption Developments and Managing Risks Mar 15, 2026 31:46 Anik A. Shah is Director & Sr. Legal Counsel, Anti-Bribery and Anti-Corruption, at Sandisk, a global semiconductor manufacturer. Anik has more than 15 years of compliance, investigations, regulatory, and law enforcement experience.Anik started his career at the U.S. Securities and Exchange Commission (SEC), where he investigated anti-fraud, anti-bribery, and other violations by multi-national

Episode 397 -- LRN's Program Effectiveness Report Mar 9, 2026 13:14 Each year, LRN’s Ethics & Compliance Program Effectiveness Report provides one of the most useful snapshots of the global compliance profession. The 2026 report—“The Next Leap: Technology, Trust, and the Transformation of Compliance”—again offers valuable insight into how corporate ethics and compliance programs are evolving amid rapid technological change, new regulatory expectations, and shi

Episode 396 -- Commerce Department Levies Second Largest Fine Against Applied Materials for Illegal Exports to China Mar 3, 2026 10:02 The Commerce Department’s Bureau of Industry and Security (BIS) has sent an unmistakable message to the semiconductor industry: creative interpretations of the Export Administration Regulations (EAR) will not shield companies from significant enforcement risk.BIS imposed a $252 million penalty against Applied Materials — the second-largest fine in the agency’s history — for illegally exporting sem

Episode 395 -- Interview of Bob Lemmond, New CEO of LRN Feb 25, 2026 25:23 Episode 395 of Corruption, Crime and Compliance features an in-depth conversation with Bob Lemmond, the new CEO of LRN, on the evolving role of ethics and compliance in today’s risk environment. In this episode, Bob discusses how organizations can move beyond “check-the-box” compliance to embed a culture of integrity that drives performance, mitigates misconduct risk, and strengthens stakeholder t

Episode 394 -- FCPA Enforcement in 2025: A Slowdown, a Policy Reset, and What the Numbers Really Mean Feb 17, 2026 10:48 FCPA enforcement in 2025 was defined by what did not happen as much as what did. Compared to prior years, the number of publicly announced cases declined sharply, corporate resolutions were fewer, and the overall enforcement posture appeared more restrained. This slowdown, however, reflects a policy recalibration—not a dismantling—of the FCPA enforcement regime.Early in the year, DOJ paused FCPA e

Episode 393 -- When Financial Controls Fail: The SEC’s ADM Settlement and the Cost of Misleading Investors Feb 15, 2026 14:08 Earlier this year, the Securities and Exchange Commission (SEC) charged Archer-Daniels-Midland Company (ADM) and three of its former executives with accounting and disclosure fraud, in what has become one of the most significant financial reporting enforcement actions of 2026. The case underscores a fundamental compliance truth: strong internal controls and transparent disclosures are not optional

Episode 392 -- The Importance of Managing Conflicts of Interest Feb 10, 2026 17:01 Conflicts of interest are not abstract compliance niceties. They are serious risks to integrity that, if left unidentified or unmitigated, can erode employee trust, compromise decision-making, and expose organizations to regulatory enforcement, litigation, and reputational harm. Recent high-profile scandals involving relationships between supervisors and subordinates have underscored how personal

Episode 391 -- DOJ's 2025 False Claims Act Report Cites $6.8 Billion in Recoveries Feb 4, 2026 13:56 The Justice Department has increased False Claims Act prosecutions, reflecting a continued focus on healthcare fraud and a new initiative on trade fraud. DOJ announced the largest annual recovery figure in the FCA's history -- $6.8 billion in settlements and recoveries.  FCA whistleblowers filed a record number of new cases -- 1,297 lawsuits and the government initiated 401 investig

Episode 390 -- A Realstic Examination of AI Risks Feb 1, 2026 12:39 From my perspective, hopefully a reasonable one, there is a little too much AI-Risk Hype. Not to belittle the experts or ignore potential risk concerns but this is getting a little carried away.  The compliance industry appears to be taken over by AI-this and AI-that. Third party risk bleeds into major AI risks, corporate governance needs to incorporate AI risks, and policies a

Episode 389 -- 2025 Review of Trade Enforcement Jan 28, 2026 10:59 The most significant compliance and enforcement issue remains trade enforcement -- sanctions and export controls. In the second posting, I want to focus on the new and interesting development in this area: the use of the False Claims Act to capture violations of tariffs and customs duties. With all the hype on the trade compliance front, when you calculate the numbers relating to crimina

Episode 388 -- Anti-Corruption Update with Scott Greytak, Transparency International, and Nate Sibley, Hudson Institute Jan 11, 2026 46:56 Scott Greytak, Transparency International, and Nate Sibley, Hudson Institute, join Michael Volkov for a review of anti-corruption issues and a look forward to the next year.

Tom Fox and Mike Volkov Discuss Compliance Issues in 2025 and Trends for 2026 (Part 2 of 2) Jan 7, 2026 22:43 Tom Fox joins Michael Volkov to discuss ethics and compliance issues for the year 2025. Tom and Mike focus on the importance of ethics, conflict of interest, trade compliance, organizational justice and other issues.This is Part 2 of a 2-Part Episode.

Tom Fox and Mike Volkov Discuss Compliance Issues in 2025 and Trends for 2026 (Part 1 of 2) Jan 5, 2026 19:53 Tom Fox joins Michael Volkov to discuss ethics and compliance issues for the year 2025. Tom and Mike focus on the importance of ethics, conflict of interest, trade compliance, organizational justice and other issues.This is Part 1 of a 2-Part episode.

[Replay] Five Strategies to Mitigate a New Risk Environment Sep 8, 2025 13:36 What do you do when the headlines shift faster than your risk matrix can keep up? In this episode, Michael Volkov dives into the challenge of adapting compliance programs in the face of volatile and fast-changing global risks—from tariffs and trade controls to supply chain disruptions and third-party exposures. While the pressure to react is constant, the real key is staying anchored in your compa

[Replay] Third-Party Risks and Sanctions Compliance Sep 1, 2025 18:35 With the beginning of the “New FCPA” era coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just the same as FCPA legal requirements. As we embark on a new criminal enforcement era surrounding sanctions violations, companies have to address this issue and do it correctly

FCPA Update: Declination and New Indictment Aug 25, 2025 10:11 Is the DOJ really changing its playbook on FCPA enforcement, or is it business as usual under a new administration? In this episode, Michael digs into two headline developments that say a lot about where things are headed - the first FCPA declination under the Trump Administration and the first indictment. Both shed light on how DOJ is applying its policies in practice, what companies should expec

AI Legal Compliance and Governance Aug 18, 2025 13:30 AI promises efficiency, innovation, and new opportunities - but are companies moving too fast in the rush to adopt it? The risks are very real, from false content to flawed decision-making, and the global regulatory patchwork is only getting more complex. The challenge now is building governance and compliance frameworks that keep pace without stifling progress.In this episode of Corruption, Crim

Episodes

Recommended