If you built your sanctions compliance program around OFAC’s 2019 Framework for Compliance Commitments and haven’t revisited it since, you’re not alone, and you’re also overdue for an update. The 2019 Framework remains the foundational document for how OFAC evaluates a sanctions compliance program, and every one of its five pillars is still good law today. But federal sanctions enforcement has fundamentally changed shape since...

Part 1 of this series traced compliance’s earliest, clumsiest attempts to measure its own programs through hotline volumes and training completion rates. Part 2 covered the shift toward continuous monitoring, integrated dashboards, and key risk indicators, a real leap forward, but one still fundamentally limited by rules-based systems that could only catch risks someone had already anticipated. Part 3 closes the series by looking at...

In this episode of Corruption, Crime and Compliance, Michael Volkov explains why OFAC’s 2019 Framework for Compliance Commitments, built on the five pillars of management commitment, risk assessment, internal controls, testing and auditing, and training, remains the essential foundation for any sanctions compliance program, while also walking through the substantial multi-agency guidance that has layered on top of it since 2023 through joint DOJ, BIS,...

Today’s version of the Trojan horse doesn’t need to sneak past your gate in the dead of night. It’s a software update to something you already let in. Second preview ahead of tomorrow’s webinar, and this one’s about a blind spot I see constantly. Most compliance officers think about shadow AI as employees going out and signing up for some random chatbot. That happens, but...

In this episode of Corruption, Crime and Compliance, Michael Volkov traces the decades-long relationship between compliance and data, from the profession’s earliest, checkbox-style attempts to measure program effectiveness through crude proxies like hotline volume and training completion rates, through the rise of continuous monitoring systems, integrated dashboards, and key risk indicators that enabled expedited auditing and near-real-time visibility, and finally to the current AI-driven era,...

Part 1 of this series traced compliance’s early, clumsy attempts to capture data about its own programs, relying on hotline volumes and training completion rates that told you very little about whether misconduct was actually being deterred or caught. It also described the gap that emerged once regulators started expecting companies to actually use their data: the systems compliance functions had simply weren’t built to...

October 28, 2026, 12 Noon EDT Sign Up HERE OFAC’s 2019 Framework for Compliance Commitments is still the foundational document every sanctions compliance program should be built on, but if your program hasn’t been updated since then, it no longer reflects how sanctions enforcement actually works today. Since 2023, the Department of Justice, the Department of Commerce’s Bureau of Industry and Security, and OFAC have...

An AI tool isn’t a piece of software. It’s a locked door, and you have no idea how many people have a key. Quick preview ahead of tomorrow’s webinar on AI and third-party risk, because I want you thinking about this before we dive in. Here’s the mental shift every compliance officer needs to make: every AI tool your company adopts is a third-party vendor...

In this episode of Corruption, Crime and Compliance, Michael Volkov rounds up three major economic policy developments happening alongside Operation Economic Outcast: the State Department’s rescission of Syria’s nearly 47-year State Sponsor of Terrorism designation, opening the door to renewed trade and eased export controls; an escalating tariff war with Canada following the collapse of USMCA renewal talks, including a 50 percent tariff on roughly...