Most companies think they have a handle on AI. Most don’t. Compliance attorney Michael Volkov has sat across the table from Fortune 500 compliance teams, major law firms, and Berkshire Hathaway subsidiaries — and what he keeps finding is “shadow AI”: people using AI at work that leadership has no idea about. In this conversation with host Collin McKee, he breaks down where the real...
Michael Volkov delivers the operational compliance program guidance companies must implement to execute safely within OFAC’s new Venezuela general license framework, structured around five program pillars: transaction scoping with mandatory lifecycle revalidation at each critical deal stage; beneficial ownership-based counterparty due diligence that goes beyond standard SDN screening to identify Russia, Iran, Cuba, North Korea, and PRC-connected ownership structures; contract review and modification to incorporate...
The United Kingdom’s Office of Financial Sanctions Implementation (OFSI) has imposed its largest Russia-related monetary penalty to date, fining travel technology company Sabre Global Technologies more than £1 million (approximately $1.3 million) for sanctions violations involving Russia’s Ural Airlines. Beyond the size of the penalty, however, the enforcement action is significant because it represents OFSI’s first sanctions circumvention case and provides a detailed roadmap of...
The Office of the U.S. Trade Representative (USTR) has launched what may be the most sweeping use of Section 301 authority in the history of American trade law. On June 2, 2026, USTR released its report and proposed action in 60 parallel investigations targeting forced labor enforcement failures across virtually every major U.S. trading partner. The proposal—covering economies that account for an estimated 99.4% of...
What separates effective trade compliance programs from ineffective ones? It starts at the top. Good, bad, or ugly, it all trickles down from the top. Here are the five keys to an effective trade compliance program. The first two are building blocks for leadership and due diligence. First, senior executives and boards must actively support trade compliance. Without leadership engagement, compliance programs become check-the-box exercises....
Most companies think they have a handle on AI. Most don’t. Compliance attorney Michael Volkov has sat across the table from Fortune 500 compliance teams, major law firms, and Berkshire Hathaway subsidiaries — and what he keeps finding is “shadow AI”: people using AI at work that leadership has no idea about. In this conversation with host Collin McKee, he breaks down where the real...
Michael Volkov delivers the operational compliance program guidance companies must implement to execute safely within OFAC’s new Venezuela general license framework, structured around five program pillars: transaction scoping with mandatory lifecycle revalidation at each critical deal stage; beneficial ownership-based counterparty due diligence that goes beyond standard SDN screening to identify Russia, Iran, Cuba, North Korea, and PRC-connected ownership structures; contract review and modification to incorporate...
The United Kingdom’s Office of Financial Sanctions Implementation (OFSI) has imposed its largest Russia-related monetary penalty to date, fining travel technology company Sabre Global Technologies more than £1 million (approximately $1.3 million) for sanctions violations involving Russia’s Ural Airlines. Beyond the size of the penalty, however, the enforcement action is significant because it represents OFSI’s first sanctions circumvention case and provides a detailed roadmap of...
The Office of the U.S. Trade Representative (USTR) has launched what may be the most sweeping use of Section 301 authority in the history of American trade law. On June 2, 2026, USTR released its report and proposed action in 60 parallel investigations targeting forced labor enforcement failures across virtually every major U.S. trading partner. The proposal—covering economies that account for an estimated 99.4% of...
What separates effective trade compliance programs from ineffective ones? It starts at the top. Good, bad, or ugly, it all trickles down from the top. Here are the five keys to an effective trade compliance program. The first two are building blocks for leadership and due diligence. First, senior executives and boards must actively support trade compliance. Without leadership engagement, compliance programs become check-the-box exercises....
On June 23, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License X (“GL X”), authorizing a broad range of transactions ordinarily incident and necessary to the production, sale, delivery, or offloading of Iranian-origin crude oil, petrochemical products, and petroleum products through August 21, 2026. The authorization applies notwithstanding prohibitions imposed under multiple Iran-related sanctions authorities and expressly...
If you read Parts I and II of this series and concluded that the AI governance problem is primarily an internal one — about what your employees do with AI inside your organization — you have only identified half the exposure. The other half lives outside your walls. It lives in your vendors, your service providers, your agents, your supply chain. And for the vast...
If Part I of this series described the governance gap at the organizational level, Part II describes the crisis that is already unfolding inside your organization right now — whether you know it or not. Shadow AI is real, it is pervasive, and the statistics are alarming. According to Gartner research across 500 companies, 68% of employees use unauthorized AI tools at work — a...
Are your employees whispering corporate secrets into the greedy ears of public-facing AI? Many organizations have no visibility into how their employees are using AI. The solution is not to ban AI. The solution is AI governance. Organizations need approved AI tools, acceptable use policies, employee training, and ongoing monitoring. Organizations need approved AI tools, acceptable use policies, employee training, and ongoing monitoring. The question...
There is a crisis unfolding in corporate boardrooms and compliance departments across America, and most organizations are not responding with anywhere near the urgency the situation demands. The crisis is AI governance — or more precisely, the near-total absence of it. The numbers are striking. According to a Compliance Week 2026 survey, 83% of organizations are using AI tools, but only 25% have implemented a...
