So approximately 10-20% of your third parties are going to present serious AI risks. How do you mitigate those risks? Here’s what you do. One, you assess your needs and identify the risk calculation for each of your third parties, and then you seek two fundamental solutions. Two, contractual provisions are critical, and there’s 6 of them that you need. You have to restrict data...
June 9, 2026 12 Noon EST Sign Up Here Third-party risk management programs are facing unprecedented challenges as companies confront heightened sanctions enforcement, corruption risks, geopolitical instability, cybersecurity threats, supply chain disruptions, and increasingly sophisticated intermediary networks. Regulators and enforcement agencies now expect companies to move beyond static due diligence questionnaires and periodic reviews toward more dynamic, data-driven, and continuously monitored third-party risk management frameworks....
In this episode of Corruption, Crime, and Compliance, Michael Volkov interviews Kilby Macfadden, J.D., CCEP, Managing Director and Associate General Counsel at KPMG LLP, where she serves as Head of Investigations overseeing complex ethics, compliance, and enterprise risk matters. Drawing on her extensive experience in government enforcement and corporate compliance, Kilby discusses the growing importance of organizational justice, building employee trust in internal reporting systems, and creating...
In this episode, we examine how organizational justice and effective internal investigation systems sit at the core of the U.S. Department of Justice evaluation of corporate compliance programs. Drawing on benchmarking data from NAVEX Global and research from George Washington University, we explain why strong speak-up cultures generate more internal reports, detect misconduct earlier, and reduce enforcement risk. We also outline DOJ expectations for timely,...
I am excited to announce the launch of our new YouTube channel — Volkov Law TV. Over the years, through Corruption, Crime & Compliance, Volkov Law webinars, podcast interviews, and speaking engagements, we have worked to provide timely analysis and practical guidance on the rapidly evolving world of corporate compliance, enforcement, sanctions, internal investigations, and corporate risk management. Volkov Law TV is the next step...
So approximately 10-20% of your third parties are going to present serious AI risks. How do you mitigate those risks? Here’s what you do. One, you assess your needs and identify the risk calculation for each of your third parties, and then you seek two fundamental solutions. Two, contractual provisions are critical, and there’s 6 of them that you need. You have to restrict data...
June 9, 2026 12 Noon EST Sign Up Here Third-party risk management programs are facing unprecedented challenges as companies confront heightened sanctions enforcement, corruption risks, geopolitical instability, cybersecurity threats, supply chain disruptions, and increasingly sophisticated intermediary networks. Regulators and enforcement agencies now expect companies to move beyond static due diligence questionnaires and periodic reviews toward more dynamic, data-driven, and continuously monitored third-party risk management frameworks....
In this episode of Corruption, Crime, and Compliance, Michael Volkov interviews Kilby Macfadden, J.D., CCEP, Managing Director and Associate General Counsel at KPMG LLP, where she serves as Head of Investigations overseeing complex ethics, compliance, and enterprise risk matters. Drawing on her extensive experience in government enforcement and corporate compliance, Kilby discusses the growing importance of organizational justice, building employee trust in internal reporting systems, and creating...
In this episode, we examine how organizational justice and effective internal investigation systems sit at the core of the U.S. Department of Justice evaluation of corporate compliance programs. Drawing on benchmarking data from NAVEX Global and research from George Washington University, we explain why strong speak-up cultures generate more internal reports, detect misconduct earlier, and reduce enforcement risk. We also outline DOJ expectations for timely,...
I am excited to announce the launch of our new YouTube channel — Volkov Law TV. Over the years, through Corruption, Crime & Compliance, Volkov Law webinars, podcast interviews, and speaking engagements, we have worked to provide timely analysis and practical guidance on the rapidly evolving world of corporate compliance, enforcement, sanctions, internal investigations, and corporate risk management. Volkov Law TV is the next step...
In Part I, we outlined how organizational justice aligns with DOJ expectations. The next step is execution—building systems that deliver fairness consistently. Timeliness: A Core DOJ Expectation The DOJ evaluates whether companies investigate misconduct promptly and effectively. Delays raise critical concerns: Companies should establish clear timelines for: Timely investigations are a hallmark of an effective compliance program. Independent Oversight: Ensuring Objectivity The DOJ places significant...
In today’s enforcement environment, the message from the U.S. Department of Justice is clear: culture, internal reporting, and investigative integrity are central to evaluating corporate compliance programs. Under the DOJ’s Evaluation of Corporate Compliance Programs (ECCP), prosecutors are directed to assess whether a company has established a system that encourages employees to report misconduct—and whether the company responds in a fair, consistent, and effective manner....
Everyone is using AI, including your third parties. Could that land you into legal trouble? Absolutely. So what are your third party AI risks? These include the standard list, data privacy risks, lack of transparency, bias and discrimination, IP and content, and of course regulatory risks. So, what can your third party do that gets you into the hot water? Well, they could be a...
In this episode, Michael Volkov analyzes the May 1 executive order signed by Donald Trump expanding U.S. sanctions targeting Cuba. The discussion highlights the order’s broad scope, including new authorities to sanction actors involved in key economic sectors, corruption, and human rights abuses, as well as its extension of secondary sanctions risk to foreign financial institutions. With increasing convergence between sanctions, anti-corruption, and human rights...
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...
