In this three-part series brought together in a single episode, Michael Volkov examines the AI governance and compliance crisis unfolding across corporate America — arguing with urgency that organizations are failing to respond at the speed and depth the risk environment demands. Drawing on the FCPA enforcement parallel, Michael first addresses the organizational AI governance gap, where surveys show 83% of companies use AI but...

Most companies think they have a handle on AI. Most don’t. Compliance attorney Michael Volkov has sat across the table from Fortune 500 compliance teams, major law firms, and Berkshire Hathaway subsidiaries — and what he keeps finding is “shadow AI”: people using AI at work that leadership has no idea about. In this conversation with host Collin McKee, he breaks down where the real...

Michael Volkov delivers the operational compliance program guidance companies must implement to execute safely within OFAC’s new Venezuela general license framework, structured around five program pillars: transaction scoping with mandatory lifecycle revalidation at each critical deal stage; beneficial ownership-based counterparty due diligence that goes beyond standard SDN screening to identify Russia, Iran, Cuba, North Korea, and PRC-connected ownership structures; contract review and modification to incorporate...

Michael Volkov examines OFAC’s new Venezuela general license framework—including General License 52, General License 46B, and the newly effective General License 51B covering Venezuelan-origin minerals—analyzing how these authorizations create conditional pathways for otherwise-prohibited energy and minerals transactions while preserving the underlying blocking regime applicable to PdVSA and the Government of Venezuela. Michael explains the established U.S. entity eligibility requirement, the mandatory contractual conditions requiring U.S....

Michael Volkov examines USTR’s unprecedented Section 301 forced labor tariff proposal, analyzing how the Trump Administration is leveraging a decades-old trade statute to rebuild broad tariff coverage following the Supreme Court’s invalidation of IEEPA emergency tariffs in Learning Resources, Inc. v. Trump. Covering economies that account for an estimated 99.4% of U.S. imports, the proposal would impose 10% duties on 14 economies with partial forced...

Michael Volkov analyzes the Commerce Department Bureau of Industry and Security’s June 12, 2026 export control directive ordering Anthropic to suspend all access to its Fable 5 and Mythos 5 AI models for any foreign national—a directive that, because Anthropic cannot segment its global user base by nationality in real time, resulted in a complete worldwide shutoff of both models for every customer. Michael places...