Corruption Crime & Compliance

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...

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...

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...

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 live...

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...

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, complianc...

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. Th...

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...

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...

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...

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...

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 dat...

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...

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, hotlin...

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...

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...

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 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 in...

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...

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...