Could your supply chain be funding cartels without you realizing it?
In today’s complex global economy, companies are grappling with a dual challenge - the urgent need to unravel their supply chains and the immediate...more
7/13/2025
/ Anti-Money Laundering ,
Beneficial Owner ,
Cartels ,
Corporate Governance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
Financial Crimes ,
Risk Management ,
Supply Chain
Is AI a magic bullet - or just another tool in the compliance toolkit?
What really happens when you let algorithms near your risk decisions?
In this episode of Corruption, Crime and Compliance, Christian Focacci, founder...more
6/15/2025
/ Algorithms ,
Artificial Intelligence ,
Compliance ,
Corporate Governance ,
Due Diligence ,
FinTech ,
Innovative Technology ,
Legal Technology ,
Machine Learning ,
Risk Management ,
Technology
What if your trade compliance misstep became tomorrow’s federal prosecution headline? In this episode, Michael Volkov issues a powerful warning to corporate leaders and compliance professionals: the DOJ is no longer treating...more
Is your company ready to bet its future on whether it can outpace a whistleblower to the DOJ’s door?
In this episode, Michael Volkov takes a deep dive into the Department of Justice’s newly announced strategy to reshape...more
DOJ’s new Corporate Enforcement Program is designed to bring certainty to the voluntary disclosure and cooperation process. DOJ’s intent is clear — voluntary disclosure is likely to lead to a declination, reduced penalties...more
5/21/2025
/ Corporate Governance ,
Corporate Misconduct ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Financial Crimes ,
Tariffs ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
For years, companies have dreaded DOJ’s potential appointment of a corporate monitorship as part of a criminal resolution. Companies have often complained about the experience, citing burdensome and sometimes unnecessary...more
With each new Administration comes a new approach or emphasis on certain enforcement priorities. The Trump Administration is marking its territory and doing so to underscore its priorities. In a recent speech, the...more
5/15/2025
/ Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
New Guidance ,
Regulatory Reform ,
Trump Administration ,
White Collar Crimes
Call me an optimist — it is a much better alternative than being a pessimist or a “realist” with a pessimistic bent. So, let’s start by acknowledging the obvious. Businesses are operating in a volatile environment. The...more
Are you running a compliance program that’s making a real impact—or just checking the boxes?
In this episode, Michael Volkov dives into LRN’s 2025 Program Effectiveness Report, an annual benchmark that separates the truly...more
LRN’s Program Effectiveness Report is an important annual event. LRN consistently provides important trend, benchmarking and program measurements. As an important leader in this area, LRN never pulls any punches. This...more
5/6/2025
/ Artificial Intelligence ,
Chief Compliance Officers ,
Compliance ,
Corporate Culture ,
Corporate Governance ,
Due Diligence ,
Emerging Technologies ,
Employee Training ,
Ethics ,
Generation Z ,
Risk Management ,
Third-Party Risk
How prepared is your organization to handle the evolving landscape of sanctions compliance? In this episode of Corruption, Crime and Compliance, Michael Volkov dives into critical sanctions compliance cases and their...more
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...more
For compliance officers, this is a stressful time. How is that for another profound grasp of the obvious? Most compliance officers face a well-known assortment of risks — bribery, trade, False Claims Act, data privacy,...more
The dust is settling and for all the drama surrounding the Trump Administration’s refocus on FCPA enforcement, the picture is becoming a little bit clearer. When cooler heads prevail, it is much easier to pick through the...more
2/14/2025
/ Anti-Corruption ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Diversity and Inclusion Standards (D&I) ,
Enforcement Actions ,
Executive Orders ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Agenda ,
Regulatory Reform ,
Trump Administration
What an amazing turn of events? — Who would have predicted that the Trump Administration would take such a bold action in the name of advancing “American Competitiveness.” I admit I did not see this coming — the Trump...more
2/12/2025
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Enforcement ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Regulatory Agenda ,
Trump Administration
Not to sound like a broken record — but we are consistently asking the compliance community the same question. As far back as March 2013, on this very blog, I wrote a posting — The Future of Compliance — What Will the New...more
In 2017, when President Trump first took office, big changes were expected in FCPA enforcement. Much of this reflected President Trump’s expressed misgivings on the substance of the FCPA. He was not a big fan of the law and...more
1/28/2025
/ Anti-Corruption ,
Compliance ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
U.S. Treasury
Criminals can be creative — that is a true statement but essentially FCPA criminals have to embrace a variety of well-established techniques to accomplish a straight-forward goal — steal money from the company to funnel...more
1/16/2025
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Governance ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Third-Party Risk ,
White Collar Crimes
C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba...more
1/14/2025
/ Acquisition Agreements ,
Civil Monetary Penalty ,
Compliance ,
Corporate Governance ,
Cuba ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Subsidiaries ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Ports ,
Regulatory Requirements ,
Risk Management ,
Sanction Violations ,
Settlement ,
Shipping
Have you ever wondered how different cultures and generations engage with a company's code of conduct? Do employees across the globe really follow ethical guidelines in the same way, or are there stark contrasts depending on...more
We continue to hear about the impact of apparent or real conflicts of interest — whether in government, in business, or in other organizations. It is an issue of significant importance. Within an organization, a perceived...more
You often hear chief compliance officers speak about benchmarking. CCOs often reveal their competitive streaks when they collect information about other companies’ compliance programs. It can easily come off as a little...more
How can companies ensure that their compliance programs are robust enough to handle today’s complex ethical challenges?
In this episode, Michael Volkov dives into the critical components of conducting an internal compliance...more
The Justice Department announced yet another version of its Evaluation of Corporate Compliance Programs. As everyone knows, the Justice Department’s guidance carries talismanic significance — it is an important document that...more
10/4/2024
/ Anti-Corruption ,
Artificial Intelligence ,
Compliance ,
Compliance Management Systems ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enterprise Risks ,
Innovative Technology ,
Machine Learning ,
Risk Management ,
White Collar Crimes
We have seen an explosion in the attention paid to legal, compliance and operational risks companies face in supply chain operations. Depending on the industry, companies have to address a wide-swath of supply chain risks,...more