When you’re conducting an internal investigation and using AI as a tool, you’re risking the use of a shifty informant. Let’s talk about a risk that I’m seeing firsthand in internal investigations: AI hallucination. I use AI in my own practice, and I got scared very quickly because it cited cases that don’t exist. It cited them confidently, persuasively, like it was reading straight off...
Ethisphere and Ethena just released a research report that every compliance officer should read carefully, not because it breaks new ground on AI risk, but because it turns the mirror around and asks an uncomfortable question: if ethics and compliance is the function writing the rules for how everyone else uses AI, why is it the function using AI the least itself? The report, based...
I was honored to appear on The Third Party Risk Association’s Podcast, TPRM Exchange, hosted by Hilary Jewhurst, to have an interesting discussion on Sanctions Compliance. The podcast is available HERE.
Michael Peregrine and Ashley Hoff recently published an interesting article on the importance of Board Vigilance on Corporate Fraud — a copy of this insightful article is available below.
On the Corruption, Crime and Compliance podcast, host Mike interviews Severin Wirtz, an in-house compliance lawyer (now at a semiconductor company, formerly at Trace International and a law firm where he cut his teeth on the Bonny Island FCPA case) about his new book, Bribery Beyond Borders, a history of the Foreign Corrupt Practices Act that took him nearly fifteen years to research and write. Wirtz argues the...
When you’re conducting an internal investigation and using AI as a tool, you’re risking the use of a shifty informant. Let’s talk about a risk that I’m seeing firsthand in internal investigations: AI hallucination. I use AI in my own practice, and I got scared very quickly because it cited cases that don’t exist. It cited them confidently, persuasively, like it was reading straight off...
Ethisphere and Ethena just released a research report that every compliance officer should read carefully, not because it breaks new ground on AI risk, but because it turns the mirror around and asks an uncomfortable question: if ethics and compliance is the function writing the rules for how everyone else uses AI, why is it the function using AI the least itself? The report, based...
I was honored to appear on The Third Party Risk Association’s Podcast, TPRM Exchange, hosted by Hilary Jewhurst, to have an interesting discussion on Sanctions Compliance. The podcast is available HERE.
Michael Peregrine and Ashley Hoff recently published an interesting article on the importance of Board Vigilance on Corporate Fraud — a copy of this insightful article is available below.
On the Corruption, Crime and Compliance podcast, host Mike interviews Severin Wirtz, an in-house compliance lawyer (now at a semiconductor company, formerly at Trace International and a law firm where he cut his teeth on the Bonny Island FCPA case) about his new book, Bribery Beyond Borders, a history of the Foreign Corrupt Practices Act that took him nearly fifteen years to research and write. Wirtz argues the...
If you’re looking at the Justice Department and only at FCPA cases, you’re looking in the wrong place. Everyone’s talking about the DOJ going soft on corporate crime. I want to push back on that narrative because I think it’s incomplete and, honestly, a little dangerous if compliance officers believe it. Yes, traditional FCPA and bribery prosecutions have slowed. But look at where the resources...
FinCEN’s $125 million penalty against UBS is notable for more than its size, though it is the largest fine ever imposed on a broker-dealer under the Bank Secrecy Act. What makes this case a critical study for compliance officers is that it is a recidivism case. UBS was fined for Bank Secrecy Act violations in 2018, and according to FinCEN’s August 3 announcement, the bank...
A federal jury sitting in Brooklyn has convicted Asante Kwaku Berko, a dual U.S.-Ghanaian citizen and former Executive Director in Goldman Sachs’ Investment Banking Division, on charges of conspiracy to violate the Foreign Corrupt Practices Act, a substantive FCPA violation, and money laundering conspiracy, following a nine-day trial. Berko later went on to serve as Managing Director of Tema Oil Refinery, one of Ghana’s major...
In this episode of Corruption, Crime and Compliance, Michael Volkov sits down with Christian Focacci, founder of Threat Digital, for their annual check-in on AI’s evolving role in due diligence and compliance. Focacci traces how AI adoption has matured from early hype and generic chatbot rollouts to more disciplined, use-case-specific tooling, while cautioning that the underlying models still hallucinate and should never be treated as...
In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down the Justice Department’s $10.2 million foreign bribery resolution with The Scoular Company, an Omaha-based agricultural supply chain company that used customs brokers to pay more than $400,000 in bribes to Mexican officials over six years so that contaminated grain shipments could cross the U.S.-Mexico border despite failed inspections. Volkov walks through the mechanics...
