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.,...

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...

In the first two articles in this series, we examined corruption’s devastating impact on economic systems and its corrosive effect on democratic institutions and political legitimacy. In this concluding piece, we turn to the dimension that receives the least attention and may be the most consequential: what corruption does to the social fabric — the norms, relationships, and shared institutions that make civil society possible....

Democracies are not destroyed overnight. They do not typically fall to tanks rolling through capital cities or dramatic coups broadcast live on state television. More often, they are hollowed out slowly, incrementally, from within — by corruption that erodes the institutions designed to hold power accountable until those institutions become shells, performing the rituals of democracy while delivering none of its substance. Corruption is democracy’s...