Author: Michael Volkov

Episode 421 — The Dangers of AI Inaccuracy — Why Human Verification Is Non-Negotiable

Artificial intelligence tools remind us every day that they can make mistakes — but in the rush to embrace AI’s extraordinary capabilities, the professional and compliance communities are not taking that warning seriously enough. In this episode, Michael Volkov draws on his own extensive experience in compliance, white-collar defense, and corporate governance to examine the real and serious dangers of AI inaccuracy in high-stakes professional...

FTI Consulting’s $1.05 Million OFAC Settlement: You Cannot Do Indirectly What You Cannot Do Directly

The Office of Foreign Assets Control delivered a pointed lesson in sanctions compliance this week with the announcement of a $1,050,000 settlement with FTI Consulting, Inc., one of the world’s most prominent business advisory firms. The enforcement action involves what might appear at first glance to be a technical violation — unpaid invoices routed through a law firm intermediary. But the compliance lessons embedded in...

Are Your Distributors Getting You Into Sanctions Trouble?

Are you ready to navigate the risky waters of third-party pirates? Most sanctions violations do not happen because companies intentionally want to evade and violate sanctions. They happen because companies trust the wrong third party. The epsilon and elf enforcement matters, which I frequently speak about, demonstrate that companies get in trouble when they have weak distributor oversight, poor intermediary screening, inadequate beneficial ownership review,...

Episode 420 – DOJ Announces New West Coast Health Care Fraud Strike Force 

The Department of Justice has announced a new West Coast Health Care Fraud Strike Force, signaling an expansion of federal enforcement efforts targeting health care fraud, telemedicine schemes, kickback arrangements, and technology-enabled billing misconduct. In this episode, Michael Volkov examines DOJ’s evolving enforcement strategy, including the growing use of data analytics and AI-driven investigations, increased scrutiny of private equity-backed health care entities, and heightened expectations...

Episode 419 — Polymarket Insider Trading Charges Illustrate DOJ and CFTC Prediction Markets Enforcement Strategy

Recent insider trading charges connected to Polymarket highlight the Department of Justice and Commodity Futures Trading Commission’s evolving enforcement strategy toward prediction markets and digital trading platforms. In this episode, Michael Volkov analyzes how regulators are applying traditional insider trading, fraud, and market manipulation theories to emerging event-based trading ecosystems. Michael also explores the growing compliance expectations for prediction market operators, including surveillance systems, AML...

Episode 418 — European Union Gives Final Approval to Landmark Anti-Corruption Directive

The European Union has formally approved its landmark Anti-Corruption Directive, creating the first comprehensive EU-wide anti-corruption framework. In this episode, Michael Volkov examines the Directive’s major provisions, including harmonized corruption offenses, expanded corporate liability, turnover-based penalties, whistleblower protections, and increased compliance expectations for multinational companies. Michael also discusses practical implications for compliance programs, third-party risk management, investigations procedures, and cross-border enforcement coordination as organizations prepare...

DOJ Indicts Chinese Shipping Container Cartel: A Wake-Up Call for Antitrust Compliance

The Justice Department’s Antitrust Division has struck a major blow against international cartel conduct with a historic superseding indictment charging four of the world’s largest shipping container manufacturers and seven of their senior executives for a multi-year conspiracy to restrict output and fix prices affecting roughly $35 billion in global commerce. The case involves conduct at the heart of America’s COVID-era supply chain crisis. And...

Can U.S. Companies Do Business in Venezuela Again?

Venezuela is a tempting new business arena. Many companies assume that Venezuela remained completely off limits. That is no longer accurate, the compliance risks are actually increasing. OFAC has issued new Venezuela related general licenses in 2026 involving oil and gas, petrochemicals, mining, critical minerals, financial services, and contingent investment negotiations. US companies are cautiously re-entering portions of the Venezuelan market under these specific licensing...

European Union Gives Final Approval to Landmark Anti-Corruption Directive

The European Union has taken a historic step in the global fight against corruption. The Council of the European Union formally adopted the EU’s first comprehensive Anti-Corruption Directive, creating a harmonized framework for corruption offenses, corporate liability, sanctions, enforcement cooperation, and prevention measures across all EU Member States. For multinational companies, compliance officers, boards of directors, and legal professionals, the Directive represents a major expansion...

Polymarket Insider Trading Charges Illustrate DOJ and CFTC Prediction Markets Enforcement Strategy

Federal prosecutors and regulators are sending an unmistakable message to the rapidly growing prediction markets industry: insider trading, market manipulation, and misuse of confidential information will not be tolerated simply because trading occurs on decentralized or event-based platforms. The recent insider trading charges involving individuals connected to prediction market trading activity underscore a broader and increasingly coordinated enforcement strategy by the Department of Justice (“DOJ”)...