Introduction: A Deal Too Good to Be True When Adani Enterprises Limited (AEL) entered the liquified petroleum gas (LPG) market in 2023, it needed a competitive edge. It found one — a Dubai-based supplier offering meaningfully discounted LPG, purportedly from Oman and Iraq. It was a compelling deal. It was also, as OFAC’s May 18, 2026 enforcement release makes clear, a sanctions disaster hiding in...
The biggest cases of corruption and fraud often have their roots in the soil of conflicts of interest. Many major corruption cases begin with something companies initially dismiss as just a conflicts issue. Conflicts of interest though are early warning signs for fraud, bribery, procurement manipulation, favoritism, and self-dealing. Weak disclosure systems allow undisclosed relationships, hidden ownership interests, and vendor manipulation. Effective programs require annual...
Artificial intelligence tools remind us every day that they can make mistakes — but in the rush to embrace AI’s extraordinary capabilities, the professional and compliance communities are not taking that warning seriously enough. In this episode, Michael Volkov draws on his own extensive experience in compliance, white-collar defense, and corporate governance to examine the real and serious dangers of AI inaccuracy in high-stakes professional...
The Office of Foreign Assets Control delivered a pointed lesson in sanctions compliance this week with the announcement of a $1,050,000 settlement with FTI Consulting, Inc., one of the world’s most prominent business advisory firms. The enforcement action involves what might appear at first glance to be a technical violation — unpaid invoices routed through a law firm intermediary. But the compliance lessons embedded in...
Are you ready to navigate the risky waters of third-party pirates? Most sanctions violations do not happen because companies intentionally want to evade and violate sanctions. They happen because companies trust the wrong third party. The epsilon and elf enforcement matters, which I frequently speak about, demonstrate that companies get in trouble when they have weak distributor oversight, poor intermediary screening, inadequate beneficial ownership review,...
Introduction: A Deal Too Good to Be True When Adani Enterprises Limited (AEL) entered the liquified petroleum gas (LPG) market in 2023, it needed a competitive edge. It found one — a Dubai-based supplier offering meaningfully discounted LPG, purportedly from Oman and Iraq. It was a compelling deal. It was also, as OFAC’s May 18, 2026 enforcement release makes clear, a sanctions disaster hiding in...
The biggest cases of corruption and fraud often have their roots in the soil of conflicts of interest. Many major corruption cases begin with something companies initially dismiss as just a conflicts issue. Conflicts of interest though are early warning signs for fraud, bribery, procurement manipulation, favoritism, and self-dealing. Weak disclosure systems allow undisclosed relationships, hidden ownership interests, and vendor manipulation. Effective programs require annual...
Artificial intelligence tools remind us every day that they can make mistakes — but in the rush to embrace AI’s extraordinary capabilities, the professional and compliance communities are not taking that warning seriously enough. In this episode, Michael Volkov draws on his own extensive experience in compliance, white-collar defense, and corporate governance to examine the real and serious dangers of AI inaccuracy in high-stakes professional...
The Office of Foreign Assets Control delivered a pointed lesson in sanctions compliance this week with the announcement of a $1,050,000 settlement with FTI Consulting, Inc., one of the world’s most prominent business advisory firms. The enforcement action involves what might appear at first glance to be a technical violation — unpaid invoices routed through a law firm intermediary. But the compliance lessons embedded in...
Are you ready to navigate the risky waters of third-party pirates? Most sanctions violations do not happen because companies intentionally want to evade and violate sanctions. They happen because companies trust the wrong third party. The epsilon and elf enforcement matters, which I frequently speak about, demonstrate that companies get in trouble when they have weak distributor oversight, poor intermediary screening, inadequate beneficial ownership review,...
On May 18, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), through its Office of Antiboycott Compliance, issued an Order resolving an antiboycott enforcement matter involving Colt’s Manufacturing Company LLC (“Colt”) arising under the Export Administration Regulations (“EAR”). The matter was resolved through a Settlement Agreement pursuant to which Colt admitted to the conduct described in a Proposed Charging Letter alleging...
The Department of Justice has announced a new West Coast Health Care Fraud Strike Force, signaling an expansion of federal enforcement efforts targeting health care fraud, telemedicine schemes, kickback arrangements, and technology-enabled billing misconduct. In this episode, Michael Volkov examines DOJ’s evolving enforcement strategy, including the growing use of data analytics and AI-driven investigations, increased scrutiny of private equity-backed health care entities, and heightened expectations...
Recent insider trading charges connected to Polymarket highlight the Department of Justice and Commodity Futures Trading Commission’s evolving enforcement strategy toward prediction markets and digital trading platforms. In this episode, Michael Volkov analyzes how regulators are applying traditional insider trading, fraud, and market manipulation theories to emerging event-based trading ecosystems. Michael also explores the growing compliance expectations for prediction market operators, including surveillance systems, AML...
The European Commission recently published an Information Note concerning measures adopted by Member States under Regulation (EU) 2021/821, the European Union’s framework governing the control of exports, brokering, technical assistance, transit, and transfer of dual-use items. Although administrative in structure, the report provides meaningful insight into the continuing evolution of export controls across the European Union and highlights the increasingly significant role that Member States...
The European Union has formally approved its landmark Anti-Corruption Directive, creating the first comprehensive EU-wide anti-corruption framework. In this episode, Michael Volkov examines the Directive’s major provisions, including harmonized corruption offenses, expanded corporate liability, turnover-based penalties, whistleblower protections, and increased compliance expectations for multinational companies. Michael also discusses practical implications for compliance programs, third-party risk management, investigations procedures, and cross-border enforcement coordination as organizations prepare...
