Corruption Crime & Compliance

In this episode, we break down the sweeping shift in U.S. sanctions policy toward Venezuela following the 2026 political transition and the issuance of multiple new general licenses by the Office of Foreign Assets Control. While the U.S. has opened the door to significant commercial activity—particularly in oil, gas, and minerals—this is not a full lifting of sanctions but a highly conditional framework with strict compliance guardrails. Companies can now engage in transactions involving Venezuelan energy and infrastructure, but must navigate complex restrictions, reporting obligations, and geopolitical limitations, including prohibitions involving Russia, Iran, and China-linked entities. This...

The final quarter of 2025 produced a modest resurgence in Foreign Corrupt Practices Act (FCPA) activity following the administration’s June 2025 FCPA guidelines. Whether that uptick signals a sustained enforcement trend remains uncertain.

But one theme remains clear: individual FCPA enforcement is alive and well.

While corporate resolutions may benefit from evolving DOJ policy and a renewed emphasis on negotiated dispositions, individuals continue to face indictment, trial, sentencing, forfeiture, and reputational destruction

In this episode of Corruption, Crime and Compliance, Michael Volkov sits down with entrepreneur and innovator Paul Allen, founder of Ancestry.com and Soar.com, to explore the evolving intersection of artificial intelligence, governance, and public trust. Paul shares insights from his latest venture, CitizenPortal.ai, an AI-powered civic intelligence platform aimed at making government activity more transparent, accessible, and accountable to everyday citizens. The conversation moves beyond hype, focusing on how AI can strengthen—not replace—democratic institutions through constrained, verifiable systems that enhance understanding and engagement. With a thoughtful and pragmatic lens, Paul discusses the risks, opportunities, and...

The U.S Department of Commerce announced two settlements recently involving export control enforcement actions.

First, the Department of Commerce’s Bureau of Industry and Security (BIS) imposed a $374,474 civil penalty against California-based satellite technology supplier Vizocom for unlawfully exporting controlled technical data related to military antennas to a Chinese manufacturer.

Second, (BIS) imposed a $1 million civil penalty against Teledyne FLIR, a U.S. manufacturer of thermal imaging cameras, for multiple violations of the Export Administration Regulations (EAR) involving exports to China and Hong Kong. The enforcement action highlights a...

In this episode, I sit down with Matthew Campbell, whose decades-long effort to seek answers about the death of his brother in the World Trade Center has now reached the doorstep of the Supreme Court of the United Kingdom.

This is not a case about liability for the September 11 attacks. Instead, it raises a fundamental constitutional question: can the UK government refuse to reopen an inquest—without meaningful judicial oversight? After the Attorney General denied Campbell’s request for a fresh inquest based on what he argues is new evidence, UK courts largely closed the...

Vera is a Chartered Accountant, Certified Internal Auditor, and award-winning Ethics and Compliance expert who writes and speaks about philosophy, business ethics, compliance, risk, and governance.

She is the Executive Director of Boards of the Future™, a non-profit that works with corporate boards globally to advocate for stronger ethics, risk, and compliance backgrounds.

She spends time between Milan and Los Angeles and serves as a Chair, director, and ethics advisor for global professional bodies, corporations, and international nonprofits.

Anik A. Shah is Director & Sr. Legal Counsel, Anti-Bribery and Anti-Corruption, at Sandisk, a global semiconductor manufacturer. Anik has more than 15 years of compliance, investigations, regulatory, and law enforcement experience.

Anik started his career at the U.S. Securities and Exchange Commission (SEC), where he investigated anti-fraud, anti-bribery, and other violations by multi-national financial institutions and technology companies and their executives.

At the SEC, Anik routinely partnered with law enforcement and regulatory authorities throughout the U.S. and in Europe, Africa, and Asia on multi-jurisdictional investigations and enforcement. He...

Each year, LRN’s Ethics & Compliance Program Effectiveness Report provides one of the most useful snapshots of the global compliance profession. The 2026 report—“The Next Leap: Technology, Trust, and the Transformation of Compliance”—again offers valuable insight into how corporate ethics and compliance programs are evolving amid rapid technological change, new regulatory expectations, and shifting workplace culture.

Based on surveys of more than 2,500 compliance professionals and employees worldwide, the report paints a picture of a profession that is progressing—but unevenly. Compliance programs are becoming more sophisticated and technologically enabled, yet many organizations are still strugg...

The Commerce Department’s Bureau of Industry and Security (BIS) has sent an unmistakable message to the semiconductor industry: creative interpretations of the Export Administration Regulations (EAR) will not shield companies from significant enforcement risk.

BIS imposed a $252 million penalty against Applied Materials — the second-largest fine in the agency’s history — for illegally exporting semiconductor manufacturing equipment to China’s Semiconductor Manufacturing International Corp. (SMIC), an Entity List company since 2020. The size of the penalty alone warrants attention. But the facts and legal analysis underlying the case provide even more important compliance lessons.

Episode 395 of Corruption, Crime and Compliance features an in-depth conversation with Bob Lemmond, the new CEO of LRN, on the evolving role of ethics and compliance in today’s risk environment. In this episode, Bob discusses how organizations can move beyond “check-the-box” compliance to embed a culture of integrity that drives performance, mitigates misconduct risk, and strengthens stakeholder trust. He shares his perspective on the growing complexity of global regulatory expectations, the importance of leadership tone and middle-management engagement, the integration of technology and data analytics into compliance programs, and the measurable business value of ethical culture. The discussion offers...

FCPA enforcement in 2025 was defined by what did not happen as much as what did. Compared to prior years, the number of publicly announced cases declined sharply, corporate resolutions were fewer, and the overall enforcement posture appeared more restrained. This slowdown, however, reflects a policy recalibration—not a dismantling—of the FCPA enforcement regime.

Early in the year, DOJ paused FCPA enforcement activity while it reviewed policy priorities. That pause, followed by the issuance of revised enforcement guidance mid-year, produced a measurable decline in announced actions. Several investigations slowed, at least one long-running prosecution was...

Earlier this year, the Securities and Exchange Commission (SEC) charged Archer-Daniels-Midland Company (ADM) and three of its former executives with accounting and disclosure fraud, in what has become one of the most significant financial reporting enforcement actions of 2026. The case underscores a fundamental compliance truth: strong internal controls and transparent disclosures are not optional — they are core risk mitigants that protect investors, markets, and corporate reputations.

At its core, the ADM matter highlights how breakdowns in accounting controls and disclosure practices — even when aimed at projecting performance — can quickly spiral into regulatory enforcement, civil penalties, and individual liabil...

Conflicts of interest are not abstract compliance niceties. They are serious risks to integrity that, if left unidentified or unmitigated, can erode employee trust, compromise decision-making, and expose organizations to regulatory enforcement, litigation, and reputational harm. Recent high-profile scandals involving relationships between supervisors and subordinates have underscored how personal conflicts can quickly morph into enterprise-wide compliance failures when controls, oversight, and ethical culture are weak.

A conflict of interest program, when thoughtfully designed and actively managed, is far more than a static policy on a shelf. It is a risk identification and mitigation engine...

The Justice Department has increased False Claims Act prosecutions, reflecting a continued focus on healthcare fraud and a new initiative on trade fraud. DOJ announced the largest annual recovery figure in the FCA's history -- $6.8 billion in settlements and recoveries. 

FCA whistleblowers filed a record number of new cases -- 1,297 lawsuits and the government initiated 401 investigations. Since 1986, DOJ has recovered a total in excess of $85 billion.

DOJ is taking full advantage of the power provisions of the FCA that include treble damages, broad liability coverage, and favorable amendments adopted to increase gover...

From my perspective, hopefully a reasonable one, there is a little too much AI-Risk Hype. Not to belittle the experts or ignore potential risk concerns but this is getting a little carried away. 

The compliance industry appears to be taken over by AI-this and AI-that. Third party risk bleeds into major AI risks, corporate governance needs to incorporate AI risks, and policies and procedures have to incorporate AI risks, while of course no risk assessment is worth its sale unless there is a discussion of dramatic AI risks.

My first response is wh...

The most significant compliance and enforcement issue remains trade enforcement -- sanctions and export controls. In the second posting, I want to focus on the new and interesting development in this area: the use of the False Claims Act to capture violations of tariffs and customs duties.

With all the hype on the trade compliance front, when you calculate the numbers relating to criminal enforcement, 2025 was a slower year than 2024. That is understandable since there is always a hiccup or delay when a new Administration takes power. 

From the administrative standpoint, howev...

Scott Greytak, Transparency International, and Nate Sibley, Hudson Institute, join Michael Volkov for a review of anti-corruption issues and a look forward to the next year.

Tom Fox joins Michael Volkov to discuss ethics and compliance issues for the year 2025. Tom and Mike focus on the importance of ethics, conflict of interest, trade compliance, organizational justice and other issues.

This is Part 2 of a 2-Part Episode.

Tom Fox joins Michael Volkov to discuss ethics and compliance issues for the year 2025. Tom and Mike focus on the importance of ethics, conflict of interest, trade compliance, organizational justice and other issues.

This is Part 1 of a 2-Part episode.

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 risks—from tariffs and trade controls to supply chain disruptions and third-party exposures. While the pressure to react is constant, the real key is staying anchored in your company’s values while making smart, timely adjustments.



Legal and compliance officers are used to adjustments and continuous improvement of their compliance programs. Building and maintaining an effective ethics and compli...

With the beginning of the “New FCPA” era coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just the same as FCPA legal requirements. As we embark on a new criminal enforcement era surrounding sanctions violations, companies have to address this issue and do it correctly. 

In this episode, Michael Volkov takes a comprehensive look at third-party risks from the distribution and supply sides and outlines appropriate strategies to manage these risks.

Is the DOJ really changing its playbook on FCPA enforcement, or is it business as usual under a new administration? In this episode, Michael digs into two headline developments that say a lot about where things are headed - the first FCPA declination under the Trump Administration and the first indictment. Both shed light on how DOJ is applying its policies in practice, what companies should expect, and why individuals are squarely in the crosshairs. Taken together, these cases remind listeners that while priorities may shift, the fundamentals of disclosure, cooperation, and accountability remain very much alive.

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AI promises efficiency, innovation, and new opportunities - but are companies moving too fast in the rush to adopt it? The risks are very real, from false content to flawed decision-making, and the global regulatory patchwork is only getting more complex. The challenge now is building governance and compliance frameworks that keep pace without stifling progress.



In this episode of Corruption, Crime, and Compliance, Michael Volkov explains why an AI compliance program is essential to corporate governance today.

You’ll hear him discuss:

What happens when a company tries to outsmart the system - and gets caught red-handed by the DOJ in a $140 million export control scheme tied to Chinese military supercomputers?

In this episode, Michael dives into the DOJ’s criminal enforcement action against Cadence Design Systems - a case that marks yet another major step in the DOJ’s rapidly unfolding trade enforcement strategy. We’re no longer in the FCPA era. This is a whole new ballgame, where national security and trade compliance have collided, and companies that haven’t adjusted are already behind.

Is your internal reporting program keeping up or falling behind the curve? With over 2.15 million reports analyzed from nearly 70 million employees worldwide, NAVEX's 2025 Regional Whistleblowing & Incident Management Benchmark Report offers a goldmine of insight into how companies are (and aren’t) managing employee concerns. In this episode, Michael Volkov breaks down the key findings, regional trends, and what they really mean for compliance officers trying to build a stronger speak-up culture. NAVEX dominates the hotline market, and its annual benchmark report gives compliance professionals an unparalleled look at reporting behaviors across the globe. From rising retaliation concerns to surprising su...

A competitor could trigger a federal investigation against your company, just by filing a whistleblower complaint about your imports. In this episode, Michael Volkov explores how the Trump Administration is reshaping the enforcement landscape by linking trade compliance and the False Claims Act (FCA) in unprecedented ways. With “trade and customs fraud, including tariff evasion” now a DOJ national priority, companies engaged in international trade face growing legal and reputational risks. A recent Ninth Circuit ruling has only intensified the stakes.

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What happens when companies ignore red flags, bypass legal advice, and underestimate the reach of U.S. export laws? In this episode, Michael Volkov unpacks two major enforcement actions from the Department of Commerce’s Bureau of Industry and Security (BIS) and the Treasury Department’s Office of Foreign Assets Control (OFAC). These cases serve as cautionary tales for companies navigating complex trade and sanctions landscapes, highlighting the steep costs of compliance failures, even when violations aren't willful.

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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 recalibration of due diligence systems to detect links to cartel and transnational criminal organizations (TCOs). With the Department of Justice sharpening its focus on both direct prosecutions and financial facilitators, global companies must prepare for heightened scrutiny. Michael breaks down the mounting risks, enforcement priorities, and practical steps companies must take to protect themselves from becoming unwitting participants in criminal operations.

What happens when a company inherits a sanctions violation through acquisition, and acts fast to fix it? Can a robust post-acquisition response really save a parent company from prosecution? In this episode, Michael Volkov unpacks the fascinating DOJ-led global enforcement action against UNICAT Catalyst Technologies - a case that reflects the U.S. government's intensifying focus on trade enforcement across sanctions, export controls, and customs. This resolution marks the first declination under DOJ’s National Security Division M&A policy, showcasing the power of voluntary disclosure, cooperation, and remediation in today’s enforcement environment.

You’...

Are your trade compliance programs truly airtight - or are they just good enough to get caught? In this episode, Michael breaks down why tariff and trade violations are now squarely on DOJ’s radar, and why the heat is rising fast for importers, especially those dealing with Chinese goods. With enforcement priorities shifting, companies are at increased risk of both regulatory investigations and full-blown criminal prosecutions. This episode is a wake-up call for compliance professionals and legal teams - if you think tariff enforcement is still a civil issue, think again.

You’ll hear...

Has the pendulum swung back on FCPA enforcement - and will companies be ready when it hits? Is the DOJ’s renewed push on FCPA enforcement a strategic shift - or just old wine in a new bottle?

In this episode, Michael discusses the return of the Justice Department to the FCPA enforcement arena. In a significant development, DOJ announced the resumption of FCPA enforcement, accompanied by a new set of enforcement guidance principles. This guidance is more than policy - it’s a statement of priorities and strategy that will shape how FCPA inve...

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 and CEO of Threat.Digital, returns for a thoughtful and highly practical conversation about the state of artificial intelligence in compliance and third-party risk management. Christian’s platform is at the forefront of using large language models and real-time data to transform how companies identify and manage risk - without losing sight of the huma...

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 trade violations as minor infractions—they're targeting them as fraud under the False Claims Act. With trade compliance now framed as a national security issue, this administration is on a mission to protect domestic industries and punish companies that cut corners. If your organization engages in international trade—especially with China—this episode is a must-listen.

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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 corporate enforcement. With promises of greater clarity, reduced penalties, and fewer monitors, the DOJ wants companies to see voluntary disclosure as a smart and safe move - not a leap of faith. But behind the incentives lies a sharper edge: whistleblowers, shortened timelines, and a more assertive DOJ ready to move fast. Whether you’re in-house counsel, a compliance office...

What happens when the world’s most influential anti-bribery law is abruptly paused? Is transparency merely a compliance box-tick—or the most powerful tool we have against global threats like kleptocracy, sanctions evasion, and illicit finance? In this eye-opening episode of Corruption, Crime, and Compliance, Michael Volkov is joined by two powerhouse experts in the global fight against corruption: Scott Greytak and Josh Birenbaum (*see ‘’About Guests below). Together, they break down the sweeping implications of the U.S. government’s pause on Foreign Corrupt Practices Act (FCPA)enforcement, the gutting of the Corporate Transparency Act (CTA), and what all of this mean...

What if your next import shipment becomes the centre of a federal enforcement action — not because of criminal intent, but because of a mistake? In today’s episode, Michael Volkov breaks down the expanding power and reach of U.S. Customs and Border Protection (CPB) and what it means for businesses navigating an increasingly aggressive trade enforcement landscape. With the Trump Administration’s re-defined objective of fair trade, companies across all sectors need to brace for scrutiny, adapt to evolving risks, and rethink their compliance strategies.

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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 impactful compliance programs from those that are merely operational. Based on insights from 1,500 global ethics and compliance professionals, this year’s report draws a clear line between high-impact and medium-impact programs—and what it takes to bridge the gap. The conversation highlights urgent risks, cultural disconnects, and the strategic value of automation, data, and leadership alignment in shaping tomorrow’s compliance functions.

When The United States has hit pause on Foreign Corrupt Practices Act (FCPA) enforcement—it left many asking whether Europe will now be stepping up to lead the global anti-corruption charge. In this episode of Corruption, Crime and Compliance, Michael Volkov explores how European prosecutors are responding to the enforcement gap, why multinational companies can’t afford to slow down their compliance efforts, and how both state-level and international initiatives are reshaping the future of anti-bribery law.

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Could your routine data transfers now violate federal law? The DOJ’s new Data Security Program (DSP) targets the flow of U.S. sensitive personal and government data to foreign adversaries — and the clock is ticking. In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down the Justice Department’s sweeping new Data Security Program, enacted under Executive Order 14117 and finalized in January 2025.

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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 implications for global companies. He discusses four significant cases that underscore the necessity of robust compliance programs, particularly in light of increased DOJ enforcement actions. Through these examples, he breaks down the consequences of third-party liability, supply chain risks, and the dangers of inadequate compliance measures, offering valuable insights into how companies can proactively avoid similar pitfalls.

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