Featured Articles:

Tariffs, OFAC and the DOJ (Part 1)

Is your trade compliance program low-hanging fruit for the Department of Justice and the regulatory agencies? The Justice Department and regulators are focused on enforcement. Civil and criminal penalties are increasing on the import side, tariffs are now a regulatory focus and also a Justice Department focus with regard to the False Claims Act. Criminal and civil penalties are coming. On the export side, traditional...

Episode 410 — Building a Best-in-Class AI Use Policy

In this episode of the Corruption, Crime & Compliance podcast, Michael Volkov examines how companies can design and implement a best-in-class AI Use Policy to manage the rapidly evolving risks associated with artificial intelligence. As organizations deploy AI tools across business functions, Volkov explains why traditional governance approaches fall short and outlines a practical framework for effective oversight, including risk-based classification of AI use cases, strict data...

Commerce Department Enforcement Actions Signal Urgent Need to Strengthen Export Control Compliance Programs

Recent enforcement actions by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) highlight a clear and consistent message for companies engaged in global trade: export control compliance programs are no longer optional—they are foundational risk management requirements. Three recent cases—two involving unlicensed exports to Entity List parties and one addressing antiboycott violations—underscore the breadth of BIS enforcement priorities and the recurring compliance...

Protecting Profit Through Ethics

It’s tempting to cut ethics and compliance in this time. But that would be a mistake. Ethics and compliance provide important fundamental values that in the end make a company more profitable. They promote employee well-being, employee engagement, and makes sure that employees have a vested interest in their company. This is not the time to start jeopardizing those important values. So keep the message...

Episode 407 — FinCEN’s AML Reform Proposal — A Shift Toward Risk, Clarity and Innovation

FinCEN’s April 2026 proposed rule marks a major shift in AML/CFT compliance by redefining how programs are evaluated, enforced, and managed under the Bank Secrecy Act. In this episode, Michael Volkov breaks down the proposal’s most significant changes, including the new two-pronged framework distinguishing program design from implementation, a higher threshold for enforcement focused on systemic failures, and expanded expectations for risk-based compliance and governance....

Third-Party AI Risk: Why Vendor Due Diligence and Onboarding Must Evolve Now

As organizations rapidly adopt artificial intelligence, many are overlooking a critical exposure point: third-party AI risk. Companies are not just deploying AI internally—they are increasingly relying on vendors, platforms, and service providers that embed AI into their offerings. From SaaS providers using generative AI to analytics vendors deploying machine learning models, AI risk is now embedded across the third-party ecosystem. This creates a fundamental shift...

What Is the ‘Ethics Premium’?

How do you convince your board that ethics and compliance pay? This is a fundamental issue that all ethics and compliance professionals need to address and communicate to the board and to your senior management. Ethics and compliance are not a cost center. The research is overwhelming that ethics and compliance provide greater financial stability and sustainability for every organization. It’s called the ethics premium,...

GE’s $36 Million ITAR Penalty — A Wake-Up Call for Export Control Compliance

The U.S. State Department’s Directorate of Defense Trade Controls (DDTC) recently imposed a $36 million penalty on General Electric (GE) for widespread violations of the International Traffic in Arms Regulations (ITAR). The enforcement action highlights persistent compliance failures across multiple dimensions — including technical data exports, licensing errors, and internal control breakdowns — and serves as a critical reminder of the risks companies face in...

Building a Best-in-Class AI Use Policy: Core Elements for an Effective Compliance Framework

As companies accelerate adoption of artificial intelligence tools across business functions, one reality is becoming increasingly clear: AI risk is not theoretical—it is operational, immediate, and enterprise-wide. From generative AI tools used in marketing and legal functions to machine learning embedded in products and decision-making systems, organizations face a rapidly evolving risk landscape that cuts across privacy, cybersecurity, intellectual property, employment law, and regulatory compliance....

Is Your AI Risk Assessment Ready? (Part 2)

Here are 3 more reasons you may think twice about letting ChatGPT run your compliance program. First, content monitoring. The content that you generate through Chat GPT or any AI service can raise real risks with regard to improper intellectual property, data privacy risks where you name certain individuals or name certain identifiers, and most importantly, remember your third-party risks. When it comes to AI...