Corruption Crime & Compliance

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 doc...

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. W...

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 ar...

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...

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 t...

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...

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...

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 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 inf...

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...

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...

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...

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 be...

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...

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 paym...

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...

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 in...

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 pro...

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...

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, a...

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...

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 a...

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...

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 d...

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...