Your company uncovers a massive criminal scheme. Are you gonna go down with the ship or are you gonna grab onto the lifeboat that the Justice Department has sent your way? The era of big corporate fines is over, and you have to make sure that you get your company through this without a big fine. What do you do? The Justice Department’s corporate enforcement...
So approximately 10-20% of your third parties are going to present serious AI risks. How do you mitigate those risks? Here’s what you do. One, you assess your needs and identify the risk calculation for each of your third parties, and then you seek two fundamental solutions. Two, contractual provisions are critical, and there’s 6 of them that you need. You have to restrict data...
In this episode of Corruption, Crime, and Compliance, Michael Volkov interviews Kilby Macfadden, J.D., CCEP, Managing Director and Associate General Counsel at KPMG LLP, where she serves as Head of Investigations overseeing complex ethics, compliance, and enterprise risk matters. Drawing on her extensive experience in government enforcement and corporate compliance, Kilby discusses the growing importance of organizational justice, building employee trust in internal reporting systems, and creating...
In this episode, we examine how organizational justice and effective internal investigation systems sit at the core of the U.S. Department of Justice evaluation of corporate compliance programs. Drawing on benchmarking data from NAVEX Global and research from George Washington University, we explain why strong speak-up cultures generate more internal reports, detect misconduct earlier, and reduce enforcement risk. We also outline DOJ expectations for timely,...
Everyone is using AI, including your third parties. Could that land you into legal trouble? Absolutely. So what are your third party AI risks? These include the standard list, data privacy risks, lack of transparency, bias and discrimination, IP and content, and of course regulatory risks. So, what can your third party do that gets you into the hot water? Well, they could be a...
In this episode, Michael Volkov analyzes the May 1 executive order signed by Donald Trump expanding U.S. sanctions targeting Cuba. The discussion highlights the order’s broad scope, including new authorities to sanction actors involved in key economic sectors, corruption, and human rights abuses, as well as its extension of secondary sanctions risk to foreign financial institutions. With increasing convergence between sanctions, anti-corruption, and human rights...
When it comes to trade compliance, don’t let the Justice Department make an example out of you and your company. Build an effective trade compliance program. Here are the steps. Step 1, get the buy-in from leadership. That means your board of directors and your senior executives. Number 2, always do a risk assessment and update it. Look at your export and import risks, identify...
In this episode of the Corruption, Crime & Compliance podcast, Michael Volkov explores the growing risks associated with third-party use of artificial intelligence and why companies must update their vendor due diligence and onboarding processes. As AI becomes embedded in SaaS platforms, analytics tools, and service providers, organizations are increasingly exposed to risks they may not fully understand or control—including data leakage, lack of transparency, bias, regulatory...
Is your trade compliance program low-hanging fruit for the Department of Justice and the regulatory agencies? The Justice Department and regulators are focused on enforcement. Civil and criminal penalties are increasing on the import side, tariffs are now a regulatory focus and also a Justice Department focus with regard to the False Claims Act. Criminal and civil penalties are coming. On the export side, traditional...
In this episode of the Corruption, Crime & Compliance podcast, Michael Volkov examines how companies can design and implement a best-in-class AI Use Policy to manage the rapidly evolving risks associated with artificial intelligence. As organizations deploy AI tools across business functions, Volkov explains why traditional governance approaches fall short and outlines a practical framework for effective oversight, including risk-based classification of AI use cases, strict data...
