PODCAST · news
Corruption Crime & Compliance
by Michael Volkov
Michael Volkov tackles the current and hot topics in the legal realms of corruption, crime, and compliance.
Episodes
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Episode 458 -- The FTC Warns 24 Major Hospital Systems
In this episode of Corruption, Crime and Compliance, Michael Volkov examines the FTC's October 5, 2026 warning letters to 24 of the nation's largest healthcare services companies, which assert that failing to provide timely, accurate, and complete pricing, particularly for scheduled…
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Can an Acquisition Create New Sanctions Risk?
You can buy a company’s assets, its customers, its brand, and guess what? Its sanctions violations. And sometimes the violation doesn’t exist until the day you close. Here’s what I mean. Under a sanctions program like Cuba and Iran, a foreign company owned by a U.S. buyer becomes subject to U.S....
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Episode 457 -- AML Compliance Shift to Effectiveness
In this episode of Corruption, Crime and Compliance, Michael Volkov examines FinCEN's April 2026 proposal to rebuild the Bank Secrecy Act AML program rule around an effectiveness standard, with a two-prong test requiring that programs be both established (risk-based, built on four core elements,...
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Are Your Export Controls Built Into the System?
If a $36 million export violation comes down to whether a loading dock worker grabbed the right box, the problem isn’t the guy on the dock. BAE Systems just paid $36 million to the State Department for more than 100 export control violations. Here’s what makes this case worth your attention. DDTC...
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Episode 456 -- Buying a Sanctions Violation
In this episode of Corruption, Crime and Compliance, Michael Volkov explains why acquiring a sanctions violation is even riskier than buying an FCPA problem: under programs like Cuba and Iran, U.S. ownership of a foreign target can itself create sanctions jurisdiction on closing day, turning...
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Can a Company Survive C-Suite Misconduct?
A pharma CEO just found out the captain doesn’t always go down with the ship. Sometimes the ship stays afloat by handing him to DOJ. Veloxis Pharmaceuticals just paid over $46 million to resolve a kickback scheme involving its kidney transplant drug, lavish meals, resort stays, payments dressed…
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Episode 455 -- Updating Your Sanctions Compliance Program
In this episode of Corruption, Crime and Compliance, Michael Volkov explains why OFAC's 2019 Framework for Compliance Commitments, built on the five pillars of management commitment, risk assessment, internal controls, testing and auditing, and training, remains the essential foundation for any...
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Is Embedded AI Slipping Past Your Controls?
Today’s version of the Trojan horse doesn’t need to sneak past your gate in the dead of night. It’s a software update to something you already let in. Second preview ahead of tomorrow’s webinar, and this one’s about a blind spot I see constantly. Most compliance officers think about shadow AI as...
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Episode 454 -- The Marriage of Compliance and Data
In this episode of Corruption, Crime and Compliance, Michael Volkov traces the decades-long relationship between compliance and data, from the profession's earliest, checkbox-style attempts to measure program effectiveness through crude proxies like hotline volume and training completion rates,...
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Is Your Third-Party Risk Program Ready for AI?
An AI tool isn’t a piece of software. It’s a locked door, and you have no idea how many people have a key. Quick preview ahead of tomorrow’s webinar on AI and third-party risk, because I want you thinking about this before we dive in. Here’s the mental shift every compliance officer needs to…
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Episode 453 -- Rounding Out Sanctions, Tariff and Trade Developments
In this episode of Corruption, Crime and Compliance, Michael Volkov rounds up three major economic policy developments happening alongside Operation Economic Outcast: the State Department's rescission of Syria's nearly 47-year State Sponsor of Terrorism designation, opening the door to renewed...
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Can DOJ Make an Indictment Disappear?
For anyone hoping a friendlier DOJ can make their old charges disappear, a federal judge just reminded us that vanishing requires his or her permission. Big development out of Brooklyn federal court. DOJ tried to drop the remaining bribery and obstruction charges against executives tied to Indian...
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Episode 452 -- Operation Economic Outcast: A Significant Expansion of Iran Sanctions and Enforcement
In this episode of Corruption, Crime and Compliance, Michael Volkov devotes a full deep dive to Operation Economic Outcast, Treasury's aggressive campaign to close off Iran's remaining financial and commercial channels following the collapse of a June 2026 US-Iran memorandum of understanding. He...
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Is Your Compliance Budget Ready for 2027?
If you’re planning for 2027 with 2025’s budget in mind, your compliance program is about to fall on its face. KPMG just surveyed 725 chief compliance officers, and the headline is simple: the job has fundamentally expanded, and if your 2027 plan doesn’t reflect that, you’re already behind. 75% of...
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Episode 451 -- Two Executives, Two Sentencings, One Week
In this episode of Corruption, Crime and Compliance, Michael Volkov examines two significant executive sentencings handed down within a day of each other: Tomás Niembro Concha, the former CEO of Puerto Rico's now-defunct Nodus International Bank, sentenced to more than nine years for a multiyear...
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When Does Board Oversight Become Bad Faith? (Part 2)
Lo and behold, Boeing gets sued over another safety crisis, and this time Boeing actually won. Want to know why? They kept the receipts. Yesterday I told you about two cases where Delaware let Caremark claims move forward. Today, the case where the board won, and its most important Caremark...
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Episode 450 -- Your Vendor Contract Template Was Not Built for AI
In this episode of Corruption, Crime and Compliance, Michael Volkov explains why standard software procurement templates fail to protect organizations in AI vendor relationships, and what to do about it. He walks through the structural differences that make AI vendors riskier than traditional...
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When Does Board Oversight Become Bad Faith? (Part 1)
Hiring someone to investigate misconduct isn’t always going to save your board. The line between bad management and bad faith just got real. Here’s a question every board member should be losing sleep over: when does a board’s failure to catch corporate misconduct cross the line from bad…
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Episode 449 -- The EU AI Act Is No Longer Theoretical
In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down why the EU AI Act has moved from a future planning exercise to an actively enforced regulatory regime, with the European Commission's AI Office holding full investigative and fining authority since August 2026, having...
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Can You Get Off the SDN List?
Has OFAC branded your company with the scarlet letter? Getting removed from the SDN list is possible, but it’s not fast, it’s not easy, and it’s not guaranteed. The primary path is a petition for administrative reconsideration filed with OFAC, arguing mistaken identity, changed circumstances, or...
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Episode 448: Caremark in 2026 — Where Delaware Draws the Line Between Bad Judgment and Bad Faith
In this episode of Corruption, Crime and Compliance, Michael Volkov examines how Delaware's Caremark doctrine has matured through a recent run of decisions involving Teligent, Regions Financial, and Boeing, all centered on the question of when a board's failure to prevent corporate misconduct...
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Is Your Sanctions Screening Enough?
Are you rubbing elbows with criminals? When OFAC designates someone a specially designated national, or SDN, it’s not a warning label. It’s a legal wall. Every asset that party has anywhere in U.S. jurisdiction, or in the hands of a U.S. person, is frozen. Every U.S. person is barred from...
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Episode 447 -- Veloxis Pharmaceuticals' $46 Million Kickback Settlement and What the CEP Really Rewards
In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down Veloxis Pharmaceuticals' more than $46 million settlement with DOJ and HHS-OIG over a years-long kickback scheme involving its kidney transplant drug Envarsus XR, a scheme the DPA says was directed in part by the...
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When You Fail to Fix an Already Flagged Compliance Gap
At $125 million, breaking the law can never be a cost of doing business. UBS Bank was hit with a $125 million FinCEN penalty, the largest ever against a broker-dealer under the Bank Secrecy Act. This is UBS’s second Bank Secrecy Act action in less than a decade. In 2018, regulators told UBS: fix...
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Episode 446 -- L3Harris's CEO Ouster and the Board Governance Lesson Nobody Learns the First Time
In this episode of Corruption, Crime and Compliance, Michael Volkov examines L3Harris Technologies' abrupt ouster of chairman and CEO Christopher Kubasik over a code-of-conduct violation, and why the story is really a board governance cautionary tale rather than a typical enforcement matter. He...
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Could Your Routine Customs Payment Actually Be a Bribe?
Is your routine payment actually a bribe? Scolar, an Omaha agricultural company, resolved an FCPA case for over $10 million after using customs brokers to bribe Mexican officials, about $2,000 for each train that crossed the border. It was invoiced as reinspection fees paid routinely for six…
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Episode 445 -- Why Your Organization Needs an AI Acceptable Use Policy
In this episode of Corruption, Crime and Compliance, Michael Volkov makes the case that every organization needs a written AI Acceptable Use Policy now, not eventually, because employees are already using AI tools with or without formal governance. He walks through the three core risk categories...
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Can Your Biggest FCPA Risk Be a Trusted Insider?
Have you heard about the Goldman Sachs banker who bribed his way to a conviction? A federal jury in Brooklyn last week convicted Asante Berko, a former Goldman Sachs executive, on FCPA conspiracy, a substantive FCPA violation, and money laundering conspiracy. Berko managed a deal between a…
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Is Trade Fraud the Next Major False Claims Act Risk?
If you think your company can smuggle and fly under the radar screen, think again. When your company touches imports, customs, or tariffs, you need to know this. The Justice Department stood up a dedicated trade fraud task force in August of last year. Its first settlement came three months…
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Episode 444 -- BAE Systems' $36 Million ITAR Wake-Up Call
In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down the State Department's $36 million settlement with BAE Systems, Inc. over more than 100 alleged violations of the International Traffic in Arms Regulations and Arms Export Control Act spanning 2019 through March 2025,...
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Where Is DOJ Taking False Claims Act Enforcement Next?
You think you can cheat the government? The False Claims Act says you’ll pay for it three times. The 2026 False Claims Act mid-year numbers are out, and the story is clear. DOJ isn’t backing down. It’s leaning in. DOJ is using the FCA (False Claims Act) to drive administration policy priorities.…
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Episode 443 -- Nothing Crosses the Border for Free
In this episode of Corruption, Crime and Compliance, Michael Volkov examines the compliance risks lurking in ordinary U.S.-Mexico cross-border trade, explaining how the plaza system allows cartels to function as a de facto taxing authority over certain border corridors, extracting piso payments...
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Could AI Use Waive Privilege in Your Internal Investigation?
When using AI in your internal investigation, make sure you protect the attorney-client privilege. A lot of investigators are feeding interview notes, documents, even witness statements into AI tools to help organize an investigation. That’s convenient, for sure, but ask yourself: where does that...
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Episode 442 -- When Forced Labor Risk Hits the P&L
In this episode of Corruption, Crime and Compliance, Michael Volkov explains why forced labor compliance has shifted from a sustainability afterthought into a direct financial and operational threat. He walks through the U.S. Trade Representative's new two-tier Section 301 tariff structure...
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Can You Trust AI During an Internal Investigation?
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...
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Episode 441 -- Severin Wirz on his New Book, "Bribery Beyond Borders: A History of the FCPA"
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...
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Are You Looking for DOJ Enforcement in the Wrong Place?
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...
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Episode 440-- Chris Focacci: AI, Due Diligence, and the Limits of Machine Judgment
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...
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Has DOJ Enforcement Shifted Rather Than Slowed Down?
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…
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Episode 439 -- The Scoular Company FCPA Resolution
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...
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Should Compliance Programs Relax When DOJ Enforcement Slows Down?
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...
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Episode 438 -- The Fight to Save the Corporate Transparency Act: An Urgent Update
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...
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Is Your Compliance Program Losing Its Seat at the Table?
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,...
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Episode 437 -- Where Your CCO Reports Tells Me Everything: The Quiet Backslide in Compliance Reporting
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…
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Is a Quiet Compliance Hotline Really Good News?
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…
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Episode 436 -- Internal Investigations and AI
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...
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What Is the Ethics Premium?
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...
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Episode 435 -- Inside the Mind of the CCO: Aaron Nicodemus on Compliance Trends, AI Governance, and Reporting Lines
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...
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Which Vendors Create the Most Risk?
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…
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Episode 434 -- Due Diligence in the Age of AI: A Conversation with Dan Greenberg
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...
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ABOUT THIS SHOW
Michael Volkov tackles the current and hot topics in the legal realms of corruption, crime, and compliance.
HOSTED BY
Michael Volkov
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Corruption Crime & Compliance currently has 502 episodes available on PodParley. New episodes are automatically indexed when they're published to the podcast feed.
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Michael Volkov tackles the current and hot topics in the legal realms of corruption, crime, and compliance.
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Corruption Crime & Compliance releases new episodes frequently with a large back catalog of 502 episodes. Check the episode list for recent publication dates.
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Corruption Crime & Compliance is created and hosted by Michael Volkov.
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