How many red flags is your company missing? We’ve seen this pattern repeatedly. A third-party red flag appears. No one knows who owns the escalation process. Business pressure overrides compliance concerns. Documentation is incomplete. Monitoring never occurs. When the regulators arrive, the company can’t demonstrate effective oversight. The problem is not simply the underlying misconduct. The problem is the inability to prove that the company...
This is Part 1 of a 3-part series on internal investigations in the age of AI. Join Michael for a webinar on September 8, 2026 on this topic — Register HERE. Every compliance professional knows the drill — the Justice Department speaks, and compliance programs adjust. When DOJ updated its Evaluation of Corporate Compliance Programs (ECCP) to address artificial intelligence and emerging technologies, most companies...
Government corruption is often viewed as a political problem, but its consequences extend far beyond government institutions. Corruption distorts economies, undermines democratic legitimacy, destroys public trust, and weakens the social fabric upon which civil society depends. In this episode, Michael Volkov explores the full impact of corruption across economic, political, and social dimensions and explains why anti-corruption compliance efforts represent far more than regulatory risk...
In the first two articles in this series, we examined corruption’s devastating impact on economic systems and its corrosive effect on democratic institutions and political legitimacy. In this concluding piece, we turn to the dimension that receives the least attention and may be the most consequential: what corruption does to the social fabric — the norms, relationships, and shared institutions that make civil society possible....
Democracies are not destroyed overnight. They do not typically fall to tanks rolling through capital cities or dramatic coups broadcast live on state television. More often, they are hollowed out slowly, incrementally, from within — by corruption that erodes the institutions designed to hold power accountable until those institutions become shells, performing the rituals of democracy while delivering none of its substance. Corruption is democracy’s...
How many red flags is your company missing? We’ve seen this pattern repeatedly. A third-party red flag appears. No one knows who owns the escalation process. Business pressure overrides compliance concerns. Documentation is incomplete. Monitoring never occurs. When the regulators arrive, the company can’t demonstrate effective oversight. The problem is not simply the underlying misconduct. The problem is the inability to prove that the company...
This is Part 1 of a 3-part series on internal investigations in the age of AI. Join Michael for a webinar on September 8, 2026 on this topic — Register HERE. Every compliance professional knows the drill — the Justice Department speaks, and compliance programs adjust. When DOJ updated its Evaluation of Corporate Compliance Programs (ECCP) to address artificial intelligence and emerging technologies, most companies...
Government corruption is often viewed as a political problem, but its consequences extend far beyond government institutions. Corruption distorts economies, undermines democratic legitimacy, destroys public trust, and weakens the social fabric upon which civil society depends. In this episode, Michael Volkov explores the full impact of corruption across economic, political, and social dimensions and explains why anti-corruption compliance efforts represent far more than regulatory risk...
In the first two articles in this series, we examined corruption’s devastating impact on economic systems and its corrosive effect on democratic institutions and political legitimacy. In this concluding piece, we turn to the dimension that receives the least attention and may be the most consequential: what corruption does to the social fabric — the norms, relationships, and shared institutions that make civil society possible....
Democracies are not destroyed overnight. They do not typically fall to tanks rolling through capital cities or dramatic coups broadcast live on state television. More often, they are hollowed out slowly, incrementally, from within — by corruption that erodes the institutions designed to hold power accountable until those institutions become shells, performing the rituals of democracy while delivering none of its substance. Corruption is democracy’s...
If your third-party risk management program uses annual questionnaires and spreadsheets, your program is already obsolete. The third-party risk environment has fundamentally changed. It used to focus on financial stability, insurance, and basic due diligence. Today, your vendors create exposures to AI risks, cybersecurity threats, sanctions violations, privacy failures, supply chain disruptions, and regulatory enforcement. Regulators are no longer asking whether you have a third-party...
Corruption is not a victimless crime. It is not an abstraction confined to bad actors in distant governments or kleptocratic regimes we read about in Foreign Affairs. It is a pernicious, systemic force that imposes a brutal and largely invisible tax on every citizen — on the price of medicine, the quality of roads, the fairness of a business license application, and the prospects of...
Tuesday, September 8, 2026 12 noon EST Sign Up HERE Artificial intelligence is rewriting the internal investigation playbook — and the Justice Department is watching. DOJ’s Evaluation of Corporate Compliance Programs directs prosecutors to ask how companies assess AI risks, whether compliance functions have real access to data and analytics resources, and what controls exist to prevent the “deliberate or reckless misuse” of new technologies....
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the UK’s Office of Financial Sanctions Implementation (OFSI) recently issued joint guidance comparing their respective sanctions regimes. While the document provides a useful overview of similarities and differences, it also sends a much broader message: international sanctions enforcement is becoming increasingly coordinated. In this episode, Michael Volkov examines why multinational companies should move beyond...
“It ain’t what you don’t know that gets you into trouble. It’s what you know for sure that just ain’t so.” — Mark Twain One of the biggest mistakes multinational companies make is assuming that U.S. and UK sanctions compliance are essentially the same. They’re not. Last week’s joint guidance issued by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the UK’s...
