In Part I of this series, we examined the collision between business pressure for AI adoption and the governance gaps that legal and compliance professionals are scrambling to address. The conflict is real, the stakes are high, and both sides of the debate have legitimate grievances. But the framing of this as a conflict between ‘speed’ and ‘safety’ is fundamentally wrong — and that misframing...
This episode examines OFAC’s new Iran General License X and why it may represent one of the most significant Iran sanctions developments in years. Michael Volkov explains what the license authorizes, why it matters amid ongoing diplomatic negotiations, and why companies should not mistake temporary sanctions relief for a permanent policy shift. The episode highlights practical compliance steps, including careful transaction analysis, documentation, due diligence,...
There is a collision happening inside boardrooms across corporate America, and it is not being broadcast in any earnings call or regulatory filing. It is playing out in conference rooms and executive Slack channels, in strategy sessions where business unit leaders are demanding faster AI adoption while legal and compliance officers are sounding alarms about governance gaps the organization has not yet filled. Both sides...
Not all sanctions violations are willful. Some companies just don’t know any better. An effective trade compliance program needs three critical elements. First, in addition to the two we spoke about in the last episode, organizations and companies have to monitor transactions, shipping documents, vessels, payment flows, and escalation of red flags. Employee training is critical. OFAC’s compliance framework specifically identifies training as a core...
Bosch agreed to pay more than $43 million in penalties and disgorgement to resolve allegations that it illegally exported products and software to Huawei in violation of U.S. export control laws. The significant enforcement action, announced jointly by the Bureau of Industry and Security (BIS) and the Department of Justice (DOJ), highlights the continuing risks associated with the Foreign Direct Product (FDP) Rule, the consequences...
In Part I of this series, we examined the collision between business pressure for AI adoption and the governance gaps that legal and compliance professionals are scrambling to address. The conflict is real, the stakes are high, and both sides of the debate have legitimate grievances. But the framing of this as a conflict between ‘speed’ and ‘safety’ is fundamentally wrong — and that misframing...
This episode examines OFAC’s new Iran General License X and why it may represent one of the most significant Iran sanctions developments in years. Michael Volkov explains what the license authorizes, why it matters amid ongoing diplomatic negotiations, and why companies should not mistake temporary sanctions relief for a permanent policy shift. The episode highlights practical compliance steps, including careful transaction analysis, documentation, due diligence,...
There is a collision happening inside boardrooms across corporate America, and it is not being broadcast in any earnings call or regulatory filing. It is playing out in conference rooms and executive Slack channels, in strategy sessions where business unit leaders are demanding faster AI adoption while legal and compliance officers are sounding alarms about governance gaps the organization has not yet filled. Both sides...
Not all sanctions violations are willful. Some companies just don’t know any better. An effective trade compliance program needs three critical elements. First, in addition to the two we spoke about in the last episode, organizations and companies have to monitor transactions, shipping documents, vessels, payment flows, and escalation of red flags. Employee training is critical. OFAC’s compliance framework specifically identifies training as a core...
Bosch agreed to pay more than $43 million in penalties and disgorgement to resolve allegations that it illegally exported products and software to Huawei in violation of U.S. export control laws. The significant enforcement action, announced jointly by the Bureau of Industry and Security (BIS) and the Department of Justice (DOJ), highlights the continuing risks associated with the Foreign Direct Product (FDP) Rule, the consequences...
In this three-part series brought together in a single episode, Michael Volkov examines the AI governance and compliance crisis unfolding across corporate America — arguing with urgency that organizations are failing to respond at the speed and depth the risk environment demands. Drawing on the FCPA enforcement parallel, Michael first addresses the organizational AI governance gap, where surveys show 83% of companies use AI but...
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...
