Corruption Crime & Compliance

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...

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 cautiou...

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 sanc...

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...

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...

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 enforcemen...

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 colle...

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...

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...

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...

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 i...

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...

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 int...

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...

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 sign...

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...

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 expo...

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...

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 me...

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 f...

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

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...

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...

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 de...

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...