Episode 465 — The Retrenchment of Compliance: Penny Wise, Pound Foolish

In this episode of Corruption, Crime and Compliance, Michael Volkov examines the growing retrenchment of compliance and why companies that cut or sideline their programs are taking on more risk, not less. Using the Bank of America penalties as a case study, he shows how a compliance function can identify the problem, recommend an exit, and still be overruled or bypassed by the business, which is a failure of stature rather than a lack of staff. He explains why the lower priority given to FCPA enforcement does not signal lower risk overall, since the administration has reallocated resources toward trade and customs enforcement, sanctions, the False Claims Act, financial crime, health care, and national security cases, including cartel-related bribery, and he notes that the $1.21 billion in Treasury penalties does not include any announced Justice Department action. Volkov closes by arguing that ethics and compliance are not cost centers but foundations of reputation, intangible asset value, and financial performance, and he offers practical steps for compliance officers and boards to restore stature, authority, and funding.











