In this episode of Corruption, Crime and Compliance, Michael Volkov examines two significant executive sentencings handed down within a day of each other: Tomás Niembro Concha, the former CEO of Puerto Rico’s now-defunct Nodus International Bank, sentenced to more than nine years for a multiyear fraud scheme that fleeced his own bank of nearly $25 million and a scheme to evade U.S. sanctions on Venezuela by secretly selling a sanctioned individual’s foreclosed home back to him through a front company; and Javier Aguilar, a former Vitol oil trader, sentenced to four years, well below the twelve DOJ sought, for bribing officials in Ecuador and Mexico to win Vitol more than $500 million in state oil company business. Volkov draws out the common threads between the two cases, shell entities, sham documentation, and years of concealment from the very oversight functions meant to catch it, and highlights Aguilar’s rejected defense that the bribes were merely industry custom as a rationalization compliance programs should treat as a red flag whenever they hear it internally.