“It ain’t what you don’t know that gets you into trouble. It’s what you know for sure that just ain’t so.” — Mark Twain One of the biggest mistakes multinational companies make is assuming that U.S. and UK sanctions compliance are essentially the same. They’re not. Last week’s joint guidance issued by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the UK’s...
Many companies carefully review each and every vendor. Almost none review their vendor’s vendor. This creates one of the biggest blind spots in modern risk management. Your payroll vendor may use a third-party AI provider. Your software company may rely on multiple subcontractors. Your logistics provider may depend on dozens of suppliers across the globe. Every one of these relationships creates additional risk. Cybercriminals are...
“However beautiful the strategy, you should occasionally look at the results.” — Winston Churchill For years, multinational companies have been hyper-focused on OFAC sanctions compliance. The UK sanctions regime was relatively quiet in impact until the global Russian sanctions hit. Now, the world has changed in many respects in the sanctions arena. Last week, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and...
Bosch agreed to pay more than $43 million in penalties and disgorgement for illegally exporting products and software to Huawei in violation of U.S. export control laws, while simultaneously receiving the first declination issued under DOJ’s revised National Security Division Corporate Enforcement Policy. In this episode, Michael Volkov examines the enforcement action, the compliance failures that led Bosch to misunderstand and misapply the Foreign Direct...
This Fourth of July is unlike any other. Two hundred and fifty years ago, a group of determined individuals gathered in Philadelphia and declared their independence, committing to a set of ideals that continue to define our nation: liberty, equality, and justice under the rule of law. As we celebrate America’s Semiquincentennial, it is worth pausing to reflect on what this milestone represents. Our nation’s...
“It ain’t what you don’t know that gets you into trouble. It’s what you know for sure that just ain’t so.” — Mark Twain One of the biggest mistakes multinational companies make is assuming that U.S. and UK sanctions compliance are essentially the same. They’re not. Last week’s joint guidance issued by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the UK’s...
Many companies carefully review each and every vendor. Almost none review their vendor’s vendor. This creates one of the biggest blind spots in modern risk management. Your payroll vendor may use a third-party AI provider. Your software company may rely on multiple subcontractors. Your logistics provider may depend on dozens of suppliers across the globe. Every one of these relationships creates additional risk. Cybercriminals are...
“However beautiful the strategy, you should occasionally look at the results.” — Winston Churchill For years, multinational companies have been hyper-focused on OFAC sanctions compliance. The UK sanctions regime was relatively quiet in impact until the global Russian sanctions hit. Now, the world has changed in many respects in the sanctions arena. Last week, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and...
Bosch agreed to pay more than $43 million in penalties and disgorgement for illegally exporting products and software to Huawei in violation of U.S. export control laws, while simultaneously receiving the first declination issued under DOJ’s revised National Security Division Corporate Enforcement Policy. In this episode, Michael Volkov examines the enforcement action, the compliance failures that led Bosch to misunderstand and misapply the Foreign Direct...
This Fourth of July is unlike any other. Two hundred and fifty years ago, a group of determined individuals gathered in Philadelphia and declared their independence, committing to a set of ideals that continue to define our nation: liberty, equality, and justice under the rule of law. As we celebrate America’s Semiquincentennial, it is worth pausing to reflect on what this milestone represents. Our nation’s...
When it comes to third-party vendors, what you don’t know is hurting you. Third parties rely on AI for customer service, recruiting, compliance screening, marketing, and decision-making. But when a third party uses AI, your organization is on the hook for legal, regulatory, contractual, and reputational risks. Organizations need to understand which third parties use AI, what tools they use, what data is being shared,...
In Part I of this series, we examined the collision between business pressure for AI adoption and the governance gaps that legal and compliance professionals are scrambling to address. The conflict is real, the stakes are high, and both sides of the debate have legitimate grievances. But the framing of this as a conflict between ‘speed’ and ‘safety’ is fundamentally wrong — and that misframing...
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,...
There is a collision happening inside boardrooms across corporate America, and it is not being broadcast in any earnings call or regulatory filing. It is playing out in conference rooms and executive Slack channels, in strategy sessions where business unit leaders are demanding faster AI adoption while legal and compliance officers are sounding alarms about governance gaps the organization has not yet filled. Both sides...
Not all sanctions violations are willful. Some companies just don’t know any better. An effective trade compliance program needs three critical elements. First, in addition to the two we spoke about in the last episode, organizations and companies have to monitor transactions, shipping documents, vessels, payment flows, and escalation of red flags. Employee training is critical. OFAC’s compliance framework specifically identifies training as a core...
