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, including careful transaction analysis, documentation, due diligence,...

In this three-part series brought together in a single episode, Michael Volkov examines the AI governance and compliance crisis unfolding across corporate America — arguing with urgency that organizations are failing to respond at the speed and depth the risk environment demands. Drawing on the FCPA enforcement parallel, Michael first addresses the organizational AI governance gap, where surveys show 83% of companies use AI but...

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...

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 Russia, Iran, Cuba, North Korea, and PRC-connected ownership structures; contract review and modification to incorporate...