When it comes to trade compliance, don’t let the Justice Department make an example out of you and your company. Build an effective trade compliance program. Here are the steps. Step 1, get the buy-in from leadership. That means your board of directors and your senior executives. Number 2, always do a risk assessment and update it. Look at your export and import risks, identify...
In this episode of the Corruption, Crime & Compliance podcast, Michael Volkov explores the growing risks associated with third-party use of artificial intelligence and why companies must update their vendor due diligence and onboarding processes. As AI becomes embedded in SaaS platforms, analytics tools, and service providers, organizations are increasingly exposed to risks they may not fully understand or control—including data leakage, lack of transparency, bias, regulatory...
On May 1, 2026, Donald Trump signed a new executive order significantly expanding U.S. sanctions targeting Cuba. The order reflects a renewed effort to tighten economic pressure on the Cuban government by broadening the scope of sanctionable conduct, increasing exposure for foreign financial institutions, and targeting corruption and human rights abuses more directly. For companies with even indirect connections to Cuba, the message is clear:...
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...
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...
When it comes to trade compliance, don’t let the Justice Department make an example out of you and your company. Build an effective trade compliance program. Here are the steps. Step 1, get the buy-in from leadership. That means your board of directors and your senior executives. Number 2, always do a risk assessment and update it. Look at your export and import risks, identify...
In this episode of the Corruption, Crime & Compliance podcast, Michael Volkov explores the growing risks associated with third-party use of artificial intelligence and why companies must update their vendor due diligence and onboarding processes. As AI becomes embedded in SaaS platforms, analytics tools, and service providers, organizations are increasingly exposed to risks they may not fully understand or control—including data leakage, lack of transparency, bias, regulatory...
On May 1, 2026, Donald Trump signed a new executive order significantly expanding U.S. sanctions targeting Cuba. The order reflects a renewed effort to tighten economic pressure on the Cuban government by broadening the scope of sanctionable conduct, increasing exposure for foreign financial institutions, and targeting corruption and human rights abuses more directly. For companies with even indirect connections to Cuba, the message is clear:...
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...
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...
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...
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...
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....
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...
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,...
