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...
For years, the Department of Justice has tried to sharpen a simple message: companies that voluntarily disclose misconduct, cooperate fully, remediate effectively—and identify responsible individuals—can earn significant credit, including declinations. The recent Balt matter is one of the clearest examples yet of that policy in action. On the one hand, DOJ issued a declination to Balt, a medical device company, despite a multi-year bribery scheme...
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,...
For years, compliance programs have operated like rearview mirrors. They looked backward, reviewed what already happened, and responded after risks had materialized. That approach is now obsolete. In today’s environment, where regulatory change moves quickly, business operations span multiple jurisdictions, and risk signals emerge from massive volumes of data, reactive compliance is a losing strategy. Companies need compliance programs that can anticipate, prioritize, and respond...
Artificial intelligence is no longer a future concept or a side experiment. It is here, and companies across every sector are racing to deploy AI tools in compliance, legal, finance, HR, procurement, cybersecurity, customer service, and operations. That creates opportunity, but it also creates risk. Too many organizations are approaching AI adoption with a mix of excitement, pressure, and improvisation. That is a mistake. AI...
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...
For years, the Department of Justice has tried to sharpen a simple message: companies that voluntarily disclose misconduct, cooperate fully, remediate effectively—and identify responsible individuals—can earn significant credit, including declinations. The recent Balt matter is one of the clearest examples yet of that policy in action. On the one hand, DOJ issued a declination to Balt, a medical device company, despite a multi-year bribery scheme...
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,...
For years, compliance programs have operated like rearview mirrors. They looked backward, reviewed what already happened, and responded after risks had materialized. That approach is now obsolete. In today’s environment, where regulatory change moves quickly, business operations span multiple jurisdictions, and risk signals emerge from massive volumes of data, reactive compliance is a losing strategy. Companies need compliance programs that can anticipate, prioritize, and respond...
Artificial intelligence is no longer a future concept or a side experiment. It is here, and companies across every sector are racing to deploy AI tools in compliance, legal, finance, HR, procurement, cybersecurity, customer service, and operations. That creates opportunity, but it also creates risk. Too many organizations are approaching AI adoption with a mix of excitement, pressure, and improvisation. That is a mistake. AI...
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,...
OFAC’s recent enforcement action against TradeStation Securities is a powerful reminder of a basic but often overlooked truth: compliance controls are only as effective as the testing, monitoring, and accountability that support them. The case is not about the absence of a compliance program—it is about the failure to ensure that the program actually worked. According to OFAC, TradeStation was fined approximately $1.1 million for...
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...
The most important aspect of DOJ’s revised Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy may be its unmistakable message to compliance professionals: a compliance program will be judged not by what it says on paper, but by whether it can drive fast, credible, and measurable action when misconduct is uncovered. This is where the unified policy has real day-to-day significance for companies. For years,...
The Department of Justice has now unified and revised its approach to corporate enforcement in a way that deserves close attention from corporate boards, general counsel, compliance officers, and white collar defense counsel. With its issuance of the Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy, DOJ has attempted to bring greater transparency and consistency to a subject that has too often depended on discretionary,...
