Category: Podcasts

Episode 440 — Chris Focacci: AI, Due Diligence, and the Limits of Machine Judgment

In this episode of Corruption, Crime and Compliance, Michael Volkov sits down with Christian Focacci, founder of Threat Digital, for their annual check-in on AI’s evolving role in due diligence and compliance. Focacci traces how AI adoption has matured from early hype and generic chatbot rollouts to more disciplined, use-case-specific tooling, while cautioning that the underlying models still hallucinate and should never be treated as...

Episode 439 — The Scoular Company FCPA Resolution

In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down the Justice Department’s $10.2 million foreign bribery resolution with The Scoular Company, an Omaha-based agricultural supply chain company that used customs brokers to pay more than $400,000 in bribes to Mexican officials over six years so that contaminated grain shipments could cross the U.S.-Mexico border despite failed inspections. Volkov walks through the mechanics...

Has DOJ Enforcement Shifted Rather Than Slowed Down?

Everyone’s talking about the DOJ going soft on crime. I want to push back on that narrative because I think it’s incomplete and, honestly, a little dangerous if compliance officers believe it. Yes, traditional FCPA and bribery prosecutions have slowed, but look at where the resources actually went. Trade enforcement is exploding. Sanctions enforcement is aggressive and getting more aggressive by the month. And here’s...

Should Compliance Programs Relax When DOJ Enforcement Slows Down?

When it comes to DOJ enforcement, the pendulum swings, and it always returns. Don’t let it knock you off your feet. I’ve been watching the headlines, and so have you. Fewer corporate guilty pleas, non-prosecution agreements for Alibaba and Eagle Bank, charges dropped against Boeing and Halkbank from Turkey. The word from Main Justice is: hold individuals accountable, go easier on companies. I get why...

Episode 438 — The Fight to Save the Corporate Transparency Act: An Urgent Update

In this update episode of Corruption, Crime and Compliance, Michael Volkov speaks with Erica Hanichak of the FACT Coalition and Frank Russo of Modern Fortis about the current fight over the Corporate Transparency Act, the 2021 law requiring companies to report their beneficial owners to a secure Treasury Department database in order to close off the U.S.’s longstanding status as an easy jurisdiction for setting...

Episode 437 — Where Your CCO Reports Tells Me Everything: The Quiet Backslide in Compliance Reporting

Episode 437 — Where Your CCO Reports Tells Me Everything: The Quiet Backslide in Compliance Reporting

Michael Volkov examines a troubling backslide in corporate governance: the quiet movement of chief compliance officers back under the general counsel after years of progress toward direct CEO reporting lines. Michael explains why the CCO’s reporting structure is the single clearest signal a company sends about the value it places on compliance — shaping whether compliance influences business strategy at the design stage or is...

Is a Quiet Compliance Hotline Really Good News?

Is a Quiet Compliance Hotline Really Good News?

In the compliance world, no news is not good news. Let me ask you a question every CCO should be asking right now: Are your employees actually reporting and using your hotline to report legitimate concerns? Too many compliance officers look at a quiet hotline and breathe a sigh of relief. No calls, no complaints. Must mean everything’s fine. I’m here to tell you that’s...

Episode 436 — Internal Investigations in the Age of AI

Episode 436 — Internal Investigations in the Age of AI

Michael Volkov examines how artificial intelligence is transforming internal investigations — and what the Justice Department now expects from companies navigating this new landscape. Michael breaks down DOJ’s updated Evaluation of Corporate Compliance Programs, which directs prosecutors to scrutinize how companies assess AI risks, whether compliance functions have adequate access to data and analytics resources, and what controls prevent the reckless misuse of new technologies....

What Is the Ethics Premium?

What Is the Ethics Premium?

The root of every strong compliance program is a strong culture. I say this on every episode, and I’m going to keep saying it. Culture is the single most important control that your compliance program builds. It’s at the heart of every compliance program—not the policy binder, not the training module. Culture. Here’s what the research really shows: companies with strong ethical cultures perform better...

Episode 435 — Inside the Mind of the CCO: Aaron Nicodemus on Compliance Trends, AI Governance, and Reporting Lines

Episode 435 — Inside the Mind of the CCO: Aaron Nicodemus on Compliance Trends, AI Governance, and Reporting Lines

In this episode of Corruption, Crime and Compliance, Michael Volkov talks with Aaron Nicodemus, editor-in-chief of Compliance Week, about the state of the compliance profession and the findings of Compliance Week’s latest “Inside the Mind of the CCO” survey. They discuss a troubling reversal in reporting lines, with more compliance officers now reporting through general counsel rather than directly to CEOs or boards after several...