Part 1 described the trends: more individuals charged, public money at the center, proactive investigations, and two competing races to the Division’s door. This post turns those trends into reminders for compliance programs. None is new; what has changed is how costly it is to forget them. Reminder 1: The Rule Has Not Changed Price fixing, bid rigging, market allocation, and output restriction are per...
Criminal antitrust used to mean international cartels, nine-figure corporate fines, and a handful of executives. The 2026 docket looks different. It is broader in industries, heavier on individuals, more proactive in its investigative methods, and increasingly built around public money. This first post identifies six trends, drawing on the Antitrust Division’s published statistics, its FY 2027 budget submission, recent speeches by Criminal Enforcement chief Daniel...
In this episode, Michael Volkov examines OFAC’s October 27, 2026 settlement with Extreme Networks, which agreed to pay $1,529,685 for nine apparent violations involving exports to MMZA, a Russian defense manufacturer blocked under the 50 percent rule through its ownership by Almaz-Antey. The company had a policy to review every Russia-related dealing, yet OFAC says it ignored red flags that included MMZA email addresses and...
On October 27, 2026, the Office of Foreign Assets Control announced a $1,529,685 settlement with Extreme Networks, Inc., a North Carolina-based AI and cloud networking provider with more than 2,800 employees in 29 countries, over nine apparent violations of the Ukraine-/Russia-Related Sanctions Regulations. The Department of Justice announced a parallel non-prosecution agreement the same day. This is a case about a company that had a...
You cannot govern AI you cannot see. That’s why the first step is not a policy. It’s an inventory. Once you’ve found every AI tool in your company, including the shadow ones, sort them into tiers. High-risk tools that make decisions about people or money, with human review of every output. Moderate risk, customer-facing tools with sampling and disclosure. Low-risk internal productivity tools on approved...
Part 1 described the trends: more individuals charged, public money at the center, proactive investigations, and two competing races to the Division’s door. This post turns those trends into reminders for compliance programs. None is new; what has changed is how costly it is to forget them. Reminder 1: The Rule Has Not Changed Price fixing, bid rigging, market allocation, and output restriction are per...
Criminal antitrust used to mean international cartels, nine-figure corporate fines, and a handful of executives. The 2026 docket looks different. It is broader in industries, heavier on individuals, more proactive in its investigative methods, and increasingly built around public money. This first post identifies six trends, drawing on the Antitrust Division’s published statistics, its FY 2027 budget submission, recent speeches by Criminal Enforcement chief Daniel...
In this episode, Michael Volkov examines OFAC’s October 27, 2026 settlement with Extreme Networks, which agreed to pay $1,529,685 for nine apparent violations involving exports to MMZA, a Russian defense manufacturer blocked under the 50 percent rule through its ownership by Almaz-Antey. The company had a policy to review every Russia-related dealing, yet OFAC says it ignored red flags that included MMZA email addresses and...
On October 27, 2026, the Office of Foreign Assets Control announced a $1,529,685 settlement with Extreme Networks, Inc., a North Carolina-based AI and cloud networking provider with more than 2,800 employees in 29 countries, over nine apparent violations of the Ukraine-/Russia-Related Sanctions Regulations. The Department of Justice announced a parallel non-prosecution agreement the same day. This is a case about a company that had a...
You cannot govern AI you cannot see. That’s why the first step is not a policy. It’s an inventory. Once you’ve found every AI tool in your company, including the shadow ones, sort them into tiers. High-risk tools that make decisions about people or money, with human review of every output. Moderate risk, customer-facing tools with sampling and disclosure. Low-risk internal productivity tools on approved...
Your supply chain doesn’t end at your supplier. Neither does your liability. Three risks are converging on the same shipments. Sanctions. Evasion networks use transshipment hubs, shell companies, and last-minute routing changes, and regulators now expect you to screen your cargo, not just your counterparties. Forced labor. U.S. law presumes goods linked to restricted regions or entities were made with forced labor unless you prove...
In this episode of Corruption, Crime and Compliance, Michael Volkov examines the growing retrenchment of compliance and why companies that cut or sideline their programs are taking on more risk, not less. Using the Bank of America penalties as a case study, he shows how a compliance function can identify the problem, recommend an exit, and still be overruled or bypassed by the business, which...
Webinar: December 2, 2026 12 Noon EST Sign Up HERE The False Claims Act has become the government’s most powerful civil fraud weapon, and enforcement has never been more aggressive. DOJ reported record FCA recoveries for fiscal year 2025, whistleblowers filed a record number of qui tam suits, and DOJ’s Trade Fraud Task Force has turned the FCA into a primary tool for pursuing tariff...
Michael Volkov examines why every organization needs a responsible AI use policy now, as employees adopt AI tools faster than companies can govern them. Drawing on court sanctions against lawyers for AI-fabricated citations, SEC “AI washing” enforcement actions, and data leaks into public chatbots, Michael explains that these failures stem from weak governance rather than weak technology. He highlights DOJ’s Evaluation of Corporate Compliance Programs,...
At a third-party risk management and supply chain conference in Chicago on Wednesday, October 28, 2026, Assistant Attorney General A. Tysen Duva, who has led the Justice Department’s Criminal Division since December 2025, delivered a message aimed squarely at boards and chief executives: fund compliance properly, and when it finds something, come to the Department early. The remarks, made in a fireside chat and reported...
