The SEC’s latest enforcement action against Merrill Lynch is a reminder that a transaction monitoring system is only as good as the calibration behind it. On July 1, 2026, Merrill agreed to pay a $7.5 million civil penalty, accept a censure, and consent to a cease-and-desist order to settle SEC charges that it failed to file numerous Suspicious Activity Reports (SARs) between April 2020 and...
In this episode of Corruption, Crime and Compliance, Michael Volkov talks with Aaron Nicodemus, editor-in-chief of Compliance Week, about the state of the compliance profession and the findings of Compliance Week’s latest “Inside the Mind of the CCO” survey. They discuss a troubling reversal in reporting lines, with more compliance officers now reporting through general counsel rather than directly to CEOs or boards after several...
Some third parties create real legal risks. Other third parties create reputational risk. Not all third parties are the same. One of the most important concepts in modern third-party risk management is distinguishing between acting vendors and incidental vendors. An acting vendor performs services on your behalf. Think customer service providers, recruiters, customs brokers, distributors, and payment processors. When these vendors use AI or engage...
On June 30, 2026, EagleBank agreed to pay more than $9.7 million to resolve a Bank Secrecy Act investigation into more than a decade of willful AML/CFT program failures tied to a check kiting scheme run by a father-son pair with a personal relationship to the bank’s own former chairman and CEO. The Justice Department’s non-prosecution agreement with EagleBank and its parent, Eagle Bancorp Inc.,...
In this episode of Corruption, Crime and Compliance, Michael Volkov sits down with Dan Greenberg, founder of Greenberg Corporate Intelligence, to unpack how due diligence and corporate investigations have evolved over Dan’s fifteen-plus years in the field. They cover the uneven state of corporate transparency worldwide, from the UK’s Companies House registry to persistent secrecy havens in the BVI, Cayman Islands, and even certain U.S....
When it comes to foreign bribery, borders provide no protection. The European Union just approved one of the most significant anti-corruption initiatives in decades, and multinational companies have to pay attention. The EU’s Anti-Corruption Directive is designed to harmonize anti-corruption enforcement across the member states. It expands corruption offenses, strengthens enforcement tools, and increases accountability for both individuals and organizations. Companies operating in Europe can...
This is Part 3 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. Most of the conversation about AI and internal investigations focuses on AI as a tool — how investigators can use it, and how to manage the risks when they do. But there is a...
This is Part 2 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. AI tools promise to transform internal investigations — faster document review, instant summaries of witness interviews, pattern detection across millions of communications. The promise is real. So are the risks. Companies rushing to deploy...
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...
