If your sanctions program is still the 2019 version, it’s missing the last seven years of enforcement. OFAC’s 2019 framework is still your foundation: management commitment, risk assessment, internal controls, testing, and training. But DOJ, Commerce, and Treasury have layered new expectations on top of that through joint Tri-Seal Notes. Four of them should be on your list today. One, U.S. nexus now reaches foreign...
The Adani prosecution has become one of the most closely watched corruption cases in the country, and not because of the facts alleged in the indictment. It is now a contest over a narrower and more consequential question: when the Justice Department decides it no longer wants to pursue a criminal case, how much of an explanation does a federal court get to demand? On...
AI is not coming to your company. It is already there. Employees are drafting emails, summarizing contracts, writing code and analyzing data with AI tools today, many on personal accounts the company never approved. If your organization does not have a responsible AI use policy, you do not have an AI strategy. You have an AI exposure. The Risk Is Not Theoretical The warning signs...
For years, a healthcare company that discovered possible wrongdoing faced two questions at once: should we tell the government, and which part of the government should hear it first? On October 15, 2026, the Justice Department’s National Fraud Enforcement Division and the Department of Health and Human Services Office of Inspector General answered the second question with a joint Policy on Coordination of Voluntary Self-Disclosure...
In this episode of Corruption, Crime and Compliance, Michael Volkov examines the more than $1.21 billion in Treasury penalties announced October 13, 2026 against Bank of America, including FinCEN’s $1.2 billion consent order, which credits the OCC’s record $750 million penalty and includes the bank’s admission that it willfully violated the Bank Secrecy Act. Volkov explains how the bank’s homegrown transaction monitoring system, Event Processor,...
If your sanctions program is still the 2019 version, it’s missing the last seven years of enforcement. OFAC’s 2019 framework is still your foundation: management commitment, risk assessment, internal controls, testing, and training. But DOJ, Commerce, and Treasury have layered new expectations on top of that through joint Tri-Seal Notes. Four of them should be on your list today. One, U.S. nexus now reaches foreign...
The Adani prosecution has become one of the most closely watched corruption cases in the country, and not because of the facts alleged in the indictment. It is now a contest over a narrower and more consequential question: when the Justice Department decides it no longer wants to pursue a criminal case, how much of an explanation does a federal court get to demand? On...
AI is not coming to your company. It is already there. Employees are drafting emails, summarizing contracts, writing code and analyzing data with AI tools today, many on personal accounts the company never approved. If your organization does not have a responsible AI use policy, you do not have an AI strategy. You have an AI exposure. The Risk Is Not Theoretical The warning signs...
For years, a healthcare company that discovered possible wrongdoing faced two questions at once: should we tell the government, and which part of the government should hear it first? On October 15, 2026, the Justice Department’s National Fraud Enforcement Division and the Department of Health and Human Services Office of Inspector General answered the second question with a joint Policy on Coordination of Voluntary Self-Disclosure...
In this episode of Corruption, Crime and Compliance, Michael Volkov examines the more than $1.21 billion in Treasury penalties announced October 13, 2026 against Bank of America, including FinCEN’s $1.2 billion consent order, which credits the OCC’s record $750 million penalty and includes the bank’s admission that it willfully violated the Bank Secrecy Act. Volkov explains how the bank’s homegrown transaction monitoring system, Event Processor,...
In this episode of Corruption, Crime and Compliance, Michael Volkov examines OFAC’s October 9, 2026 settlement with Pegasus Worldwide Logistics, a small California freight forwarder that agreed to pay $175,015 for apparent violations of counter narcotics sanctions and OFAC reporting obligations. Pegasus arranged the shipment of a $5,950 sugar packet-filling machine from a China-based supplier that had been designated, but had changed its name while...
Compliance used to count training completions. Today, regulators want proof your program actually works. That shift didn’t happen by accident. Twenty years ago, compliance data meant hotline calls and a training checklist. The numbers were easy to collect and nearly impossible to interpret. A quiet hotline could mean a great culture or a terrified workforce. Then regulators started asking harder questions: Do you track your...
On October 9, 2026, OFAC announced a $175,015 settlement with Pegasus Worldwide Logistics, a California freight forwarder of about a dozen employees. The dollar figure is modest, and the shipment at the center of the case was a machine worth $5,950. But the action is one of the clearest recent illustrations of how an ordinary trade transaction becomes a sanctions violation, and it speaks directly...
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...
