Category: Podcasts

Episode 316 — DOJ Announces New Whistleblower Program and Encourages Self-Disclosures

In a recent speech, on March 7, 2024, Deputy Attorney General Monaco announced that DOJ would be implementing in the next 90 days a new whistleblower program to reward reporting of criminal misconduct at both public and private companies.  In particular DOJ will encourage reporting of potential violations of the Foreign Corrupt Practices Act (“FCPA”) and the recently-enacted  Foreign Extortion Prevention Act (“FEPA”). AAG Monaco...

Episode 315 — Boeing Pays $51 Million for ITAR Violations

Boeing continues to struggle with its core business activities. As troubles mount for Boeing, it  is clear that it continues to suffer from real and pervasive culture issues that have been reflected in serious safety failures, financial difficulties, regulatory violations and serious reputational damage.  Boeing’s troubles permeate every part of its organization — from the board to senior executives, to its operations and its overall...

Episode 314 — A Deep Dive into DOJ’s Gunvor FCPA Enforcement Action

In a recent blockbuster FCPA settlement, DOJ announced a $661 million resolution with Gunvor, one of the world’s largest commodities trading companies. DOJ’s settlement represents a “return” to its long-standing aggressive approach to FCPA enforcement. DOJ did not permit Gunvor to enter into a deferred or non-prosecution agreement. Instead, DOJ required Gunvor to plead guilty to one count of FCPA conspiracy. Gunvor entered into a...

Episode 313 — The Coming Sanctions Criminal Corporate Enforcement Storm

There are some things you learn best in calm, and some in storm.  Will Cather DOJ has promised an aggressive criminal corporate enforcement program against sanctions violators. The storm is coming and will arrive soon with a bang. There is no question that DOJ’s enforcement initiative is coming — it is just a question as to when. In this Episode, Michael Volkov reviews the elements...

Episode 312 — Eddie Green, CEO of SnippetSentry, on Communications Preservation Risks

Episode 312 — Eddie Green, CEO of SnippetSentry, on Communications Preservation Risks

Companies have a vested interest in preserving internal communications for a variety of reasons — to hold actors accountable and to protect the organization from potential private and government claims or investigations that may have serious direct or collateral consequences. Companies that want to use ephemeral messaging systems can do so, but they have to understand the risks involved and tailor appropriate controls and procedures...

Episode 311: Tom Fox on FCPA Enforcement — DOJ’s Approach to Recidivism and Self-Disclosure

In this special episode of Corruption, Crime, and Compliance, Michael Volkov joins colleague and long-time friend Tom Fox as they delve into the intricacies of recent FCPA enforcement actions, shedding light on the evolving landscape of corporate compliance. From the ABB case to the SAP settlement, Michael and Tom dissect the nuances of voluntary disclosure, extensive remediation, and the shifting priorities of the Department of...

Episode 310 — Christian Focacci, CEO and Founder, Threat.Digital, on AI and Compliance

Episode 310 — Christian Focacci, CEO and Founder, Threat.Digital, on AI and Compliance

Christian Focacci is a leader in the artificial intelligence world and harnesses the capabilities for risk management. He is the founder and CEO of Threat.Digital, which has launched a new product DiligenAI.  Threat.Digital is leveraging large language models and real-time data feeds to empower organizations to identify risk information confidently and efficiently, setting a new standard in risk intelligence. Mike and Christian discuss AI and...

Episode 309 — Alex Cotoia on Compliance with Uyghur Forced Labor Prevention Act

Episode 309 — Alex Cotoia on Compliance with Uyghur Forced Labor Prevention Act

On December 31, 2021, President Joseph R. Biden, Jr. signed the the Uyghur Forced Labor Prevention Act (“UFLPA”) into law to address the ongoing exploitation of the ethnic minority Uyghur population by the government of the People’s Republic of China (“PRC”). Among other things, the UFLPA creates a rebuttable presumption that all goods, wares, articles, and merchandise mined, produced, or manufactured wholly or in part...

Episode 308 — Gabrielle Griffith, Director BPE Global, on Trade Compliance Trends and Expectations

Gabrielle Griffith, Director BPE Global, is an expert in trade compliance issues. Gabrielle assists clients in implementing effective trade compliance programs by addressing improvements within organizations’ people, processes, and systems. In the area of U.S. export controls, she advises clients on compliance with the International Traffic in Arms Regulations, the U.S. Export Administration Regulations, and the various embargo and sanctions programs administered by the Office...

Episode 307 — Sanctions Enforcement Review and Predictions for 2024

Episode 307 — Sanctions Enforcement Review and Predictions for 2024

DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals.  DOJ has warned everyone, repeated this message in various speeches and, most importantly, assigned the resources — 25 new federal prosecutors to enforce sanctions and export controls — to back up its enforcement program. The new model for sanctions corporate enforcement will look like FCPA enforcement —...