Every so often, corporate governance debates that we thought were settled come roaring back. The reporting line for the chief compliance officer is one of them. For years, the trend line pointed in the right direction — more companies elevating the CCO to report directly to the CEO, with independent access to the board. Lately, I am seeing troubling signs of backsliding, with companies quietly...

The individual prosecutions now flowing out of the TD Bank money laundering scandal are a reminder that institutional control failures are ultimately executed, or ignored, one employee at a time. This week, U.S. District Judge Esther Salas sentenced former TD Bank assistant manager Wilfredo Aquino to 46 months in prison and three years of probation for his role in a money laundering conspiracy that moved...

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...

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...