Has OFAC branded your company with the scarlet letter? Getting removed from the SDN list is possible, but it’s not fast, it’s not easy, and it’s not guaranteed. The primary path is a petition for administrative reconsideration filed with OFAC, arguing mistaken identity, changed circumstances, or that the original factual basis was simply wrong.You must prove it with real documented evidence. OFAC is skeptical of...
In this episode of Corruption, Crime and Compliance, Michael Volkov examines how Delaware’s Caremark doctrine has matured through a recent run of decisions involving Teligent, Regions Financial, and Boeing, all centered on the question of when a board’s failure to prevent corporate misconduct crosses from ordinary mismanagement into an actual breach of the duty of loyalty. He walks through Teligent’s officer-level oversight failures in FDA...
KPMG just released its 2026 Global Chief Ethics and Compliance Officer Survey, drawing on responses from 725 CCOs, and the framing KPMG chose for the report tells you most of what you need to know before you even get to the data: “Feeling the pressure: A new reality for compliance leaders.” That’s not marketing language. It reflects a genuine shift in what the compliance function...
The UK’s Office of Financial Sanctions Implementation fined Citibank’s London branch roughly 4.7 million pounds, about $6.4 million, for violating Russia sanctions, and this case deserves close attention from every financial institution compliance team, not because the violations were exotic or novel, but because they weren’t. This is a case study in ordinary operational failure at scale: screening systems that missed a name variant, alert...
Are you rubbing elbows with criminals? When OFAC designates someone a specially designated national, or SDN, it’s not a warning label. It’s a legal wall. Every asset that party has anywhere in U.S. jurisdiction, or in the hands of a U.S. person, is frozen. Every U.S. person is barred from transacting with them, directly or indirectly. The trap is OFAC’s 50% rule, which means any...
Has OFAC branded your company with the scarlet letter? Getting removed from the SDN list is possible, but it’s not fast, it’s not easy, and it’s not guaranteed. The primary path is a petition for administrative reconsideration filed with OFAC, arguing mistaken identity, changed circumstances, or that the original factual basis was simply wrong.You must prove it with real documented evidence. OFAC is skeptical of...
In this episode of Corruption, Crime and Compliance, Michael Volkov examines how Delaware’s Caremark doctrine has matured through a recent run of decisions involving Teligent, Regions Financial, and Boeing, all centered on the question of when a board’s failure to prevent corporate misconduct crosses from ordinary mismanagement into an actual breach of the duty of loyalty. He walks through Teligent’s officer-level oversight failures in FDA...
KPMG just released its 2026 Global Chief Ethics and Compliance Officer Survey, drawing on responses from 725 CCOs, and the framing KPMG chose for the report tells you most of what you need to know before you even get to the data: “Feeling the pressure: A new reality for compliance leaders.” That’s not marketing language. It reflects a genuine shift in what the compliance function...
The UK’s Office of Financial Sanctions Implementation fined Citibank’s London branch roughly 4.7 million pounds, about $6.4 million, for violating Russia sanctions, and this case deserves close attention from every financial institution compliance team, not because the violations were exotic or novel, but because they weren’t. This is a case study in ordinary operational failure at scale: screening systems that missed a name variant, alert...
Are you rubbing elbows with criminals? When OFAC designates someone a specially designated national, or SDN, it’s not a warning label. It’s a legal wall. Every asset that party has anywhere in U.S. jurisdiction, or in the hands of a U.S. person, is frozen. Every U.S. person is barred from transacting with them, directly or indirectly. The trap is OFAC’s 50% rule, which means any...
U.S. District Judge Nicholas Garaufis has rejected the Justice Department’s request to drop the remaining bribery and obstruction of justice charges against executives connected to Indian billionaire Gautam Adani’s conglomerate, and this ruling deserves attention well beyond the Adani matter itself. It’s a rare and pointed example of a federal court refusing to simply accept a prosecutor’s word that dismissal is warranted, and it raises...
Part 1 of this series walked through the settlement terms and the sheer range of violations DDTC documented against BAE Systems, spanning unlicensed technical data exports, unauthorized defense services, agreement mismanagement, and documentation failures. In Part 2, we focus on what actually caused all of this, because DDTC’s charging letter is unusually candid about root causes, and those root causes are far more instructive than...
If your organization does not yet have a written AI Acceptable Use Policy, I can tell you exactly what is happening inside your walls right now: employees are already using AI tools, whether you have authorized it or not. They are pasting documents into chatbots to summarize them, asking generative AI to draft correspondence, running research queries, and increasingly relying on AI features quietly embedded...
Part 1 of this series laid out why the risk landscape around generative AI, confidentiality exposure, hallucination risk, and vendor risk, makes a written AI Acceptable Use Policy an urgent priority rather than a nice-to-have. In Part 2, I want to walk through what actually needs to be in that policy for it to function as a real governance tool rather than a document nobody...
In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down Veloxis Pharmaceuticals’ more than $46 million settlement with DOJ and HHS-OIG over a years-long kickback scheme involving its kidney transplant drug Envarsus XR, a scheme the DPA says was directed in part by the company’s own former CEO. He examines why Veloxis avoided prosecution and instead secured a deferred prosecution agreement under DOJ’s...
