It’s tempting to cut ethics and compliance in this time. But that would be a mistake. Ethics and compliance provide important fundamental values that in the end make a company more profitable. They promote employee well-being, employee engagement, and makes sure that employees have a vested interest in their company. This is not the time to start jeopardizing those important values. So keep the message...
FinCEN’s April 2026 proposed rule marks a major shift in AML/CFT compliance by redefining how programs are evaluated, enforced, and managed under the Bank Secrecy Act. In this episode, Michael Volkov breaks down the proposal’s most significant changes, including the new two-pronged framework distinguishing program design from implementation, a higher threshold for enforcement focused on systemic failures, and expanded expectations for risk-based compliance and governance....
How do you convince your board that ethics and compliance pay? This is a fundamental issue that all ethics and compliance professionals need to address and communicate to the board and to your senior management. Ethics and compliance are not a cost center. The research is overwhelming that ethics and compliance provide greater financial stability and sustainability for every organization. It’s called the ethics premium,...
Here are 3 more reasons you may think twice about letting ChatGPT run your compliance program. First, content monitoring. The content that you generate through Chat GPT or any AI service can raise real risks with regard to improper intellectual property, data privacy risks where you name certain individuals or name certain identifiers, and most importantly, remember your third-party risks. When it comes to AI...
Artificial intelligence is rapidly transforming business operations—but it is also introducing a new generation of legal, ethical, and compliance risks. In this episode, we explore how AI risk is accelerating across organizations, from data leakage and bias to over-reliance on flawed outputs and hidden third-party exposure. Drawing on real enforcement trends and practical examples, we explain why AI risk is fundamentally a human and governance...
Are you actually thinking of turning over your compliance program to ChatGPT? If so, you need to listen to this. AI has to be implemented in a methodical way, a step-by-step program. So let’s talk about those steps. First, you need a governance structure, meaning you have to have an organization responsible across the entire organization for all your uses of AI. Second, like every...
In this episode, we examine the Department of Justice’s declination in the Balt Medical case—a textbook example of how DOJ is applying its Corporate Enforcement Policy in practice. Despite a multi-year foreign bribery scheme involving payments to a physician at a state-owned hospital, DOJ declined to prosecute the company based on its timely self-disclosure, full cooperation, and effective remediation. But the real story lies in...
In this episode, we break down the sweeping shift in U.S. sanctions policy toward Venezuela following the 2026 political transition and the issuance of multiple new general licenses by the Office of Foreign Assets Control. While the U.S. has opened the door to significant commercial activity—particularly in oil, gas, and minerals—this is not a full lifting of sanctions but a highly conditional framework with strict...
The final quarter of 2025 produced a modest resurgence in Foreign Corrupt Practices Act (FCPA) activity following the administration’s June 2025 FCPA guidelines. Whether that uptick signals a sustained enforcement trend remains uncertain. But one theme remains clear: individual FCPA enforcement is alive and well. While corporate resolutions may benefit from evolving DOJ policy and a renewed emphasis on negotiated dispositions, individuals continue to face indictment,...
In this episode of Corruption, Crime and Compliance, Michael Volkov sits down with entrepreneur and innovator Paul Allen, founder of Ancestry.com and Soar.com, to explore the evolving intersection of artificial intelligence, governance, and public trust. Paul shares insights from his latest venture, CitizenPortal.ai, an AI-powered civic intelligence platform aimed at making government activity more transparent, accessible, and accountable to everyday citizens. The conversation moves beyond hype,...
