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...
If your third-party risk management program uses annual questionnaires and spreadsheets, your program is already obsolete. The third-party risk environment has fundamentally changed. It used to focus on financial stability, insurance, and basic due diligence. Today, your vendors create exposures to AI risks, cybersecurity threats, sanctions violations, privacy failures, supply chain disruptions, and regulatory enforcement. Regulators are no longer asking whether you have a third-party...
Corruption is not a victimless crime. It is not an abstraction confined to bad actors in distant governments or kleptocratic regimes we read about in Foreign Affairs. It is a pernicious, systemic force that imposes a brutal and largely invisible tax on every citizen — on the price of medicine, the quality of roads, the fairness of a business license application, and the prospects of...
“It ain’t what you don’t know that gets you into trouble. It’s what you know for sure that just ain’t so.” — Mark Twain One of the biggest mistakes multinational companies make is assuming that U.S. and UK sanctions compliance are essentially the same. They’re not. Last week’s joint guidance issued by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the UK’s...
Many companies carefully review each and every vendor. Almost none review their vendor’s vendor. This creates one of the biggest blind spots in modern risk management. Your payroll vendor may use a third-party AI provider. Your software company may rely on multiple subcontractors. Your logistics provider may depend on dozens of suppliers across the globe. Every one of these relationships creates additional risk. Cybercriminals are...
“However beautiful the strategy, you should occasionally look at the results.” — Winston Churchill For years, multinational companies have been hyper-focused on OFAC sanctions compliance. The UK sanctions regime was relatively quiet in impact until the global Russian sanctions hit. Now, the world has changed in many respects in the sanctions arena. Last week, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and...
This Fourth of July is unlike any other. Two hundred and fifty years ago, a group of determined individuals gathered in Philadelphia and declared their independence, committing to a set of ideals that continue to define our nation: liberty, equality, and justice under the rule of law. As we celebrate America’s Semiquincentennial, it is worth pausing to reflect on what this milestone represents. Our nation’s...
When it comes to third-party vendors, what you don’t know is hurting you. Third parties rely on AI for customer service, recruiting, compliance screening, marketing, and decision-making. But when a third party uses AI, your organization is on the hook for legal, regulatory, contractual, and reputational risks. Organizations need to understand which third parties use AI, what tools they use, what data is being shared,...
