Nearly every company has a code of conduct, and nearly every employee has signed off on it. That is the good news in LRN’s 2026 Code of Conduct Report, “The Culture Behind the Code.” The harder news is that the signature may be doing most of the work. The report combines an analysis of more than 1,000 codes with a survey of roughly 2,000 employees...
For decades, the legal test for an anti-money laundering program under the Bank Secrecy Act has been, in practice, a test of completeness. Did the institution have written policies? A designated compliance officer? Independent testing? Training? Examiners checked for the pillars, and an institution with all of them in place could reasonably feel it had met its obligation, even if no one could say whether...
In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down DOJ Directive 26-12, the October 1, 2026 memorandum in which Assistant Attorney General Colin McDonald sets corporate enforcement policy for the National Fraud Enforcement Division. He explains the Division’s four investigative priorities, health care, procurement and government contracts, revenue evasion, and tariff evasion, import and forced labor schemes, and walks through the ten...
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, non-emergency care, can be a deceptive or unfair practice under Section 5 of the FTC Act, and that incomplete disclosures omitting physician or facility...
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. sanctions the moment the deal closes. Business that was lawful on Monday can be...
Nearly every company has a code of conduct, and nearly every employee has signed off on it. That is the good news in LRN’s 2026 Code of Conduct Report, “The Culture Behind the Code.” The harder news is that the signature may be doing most of the work. The report combines an analysis of more than 1,000 codes with a survey of roughly 2,000 employees...
For decades, the legal test for an anti-money laundering program under the Bank Secrecy Act has been, in practice, a test of completeness. Did the institution have written policies? A designated compliance officer? Independent testing? Training? Examiners checked for the pillars, and an institution with all of them in place could reasonably feel it had met its obligation, even if no one could say whether...
In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down DOJ Directive 26-12, the October 1, 2026 memorandum in which Assistant Attorney General Colin McDonald sets corporate enforcement policy for the National Fraud Enforcement Division. He explains the Division’s four investigative priorities, health care, procurement and government contracts, revenue evasion, and tariff evasion, import and forced labor schemes, and walks through the ten...
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, non-emergency care, can be a deceptive or unfair practice under Section 5 of the FTC Act, and that incomplete disclosures omitting physician or facility...
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. sanctions the moment the deal closes. Business that was lawful on Monday can be...
On October 5, the Federal Trade Commission sent warning letters to 24 of the nation’s largest healthcare services companies, telling them that they have a legal obligation to give patients timely, accurate, and complete pricing information, and that failing to do so can be an unfair or deceptive practice under Section 5 of the FTC Act. The agency did not name the recipients. But the...
Companies that sell software often think of an export as a physical event: a box leaves the warehouse. The Commerce Department’s latest settlement with Lambda Research Corporation is a pointed reminder that for software companies, the export may be an automatic update pushed to a customer overseas months or years after the original sale. The Bureau of Industry and Security announced the settlement on Friday,...
On October 1, 2026, Assistant Attorney General Colin McDonald issued Directive 26-12 to all personnel of the Department of Justice’s National Fraud Enforcement Division. The five-page memorandum, titled “Corporate Enforcement in the Fight Against Fraud,” is addressed to prosecutors, but compliance officers and general counsel should read it as if it were addressed to them. It identifies the fraud schemes that will receive priority, lists...
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, and kept current) and maintained (implemented in all material respects), along with a new enforcement threshold for banks limited to significant...
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 didn’t find willful evasion. It found something more common and, honestly, scarier: a...
