In this episode of Corruption, Crime and Compliance, Michael Volkov explains why standard software procurement templates fail to protect organizations in AI vendor relationships, and what to do about it. He walks through the structural differences that make AI vendors riskier than traditional software vendors, multi-layered data flows through underlying foundation models, frequent model swaps, and vendors’ commercial incentive to train on customer data, and...

Hiring someone to investigate misconduct isn’t always going to save your board. The line between bad management and bad faith just got real. Here’s a question every board member should be losing sleep over: when does a board’s failure to catch corporate misconduct cross the line from bad management into an actual breach of fiduciary duty? Delaware just gave us two new answers, and they...

In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down why the EU AI Act has moved from a future planning exercise to an actively enforced regulatory regime, with the European Commission’s AI Office holding full investigative and fining authority since August 2026, having already opened its first formal investigations in June 2026 into hiring tools, credit scoring systems, and student monitoring applications....

I wasa honored to appear recently on Greg Rasner’s Third Party Threat Hunters Podcast to discuss Third-Party Sanctions Risk. You can listen to it HERE. Thanks to Greg and his incredible team.

Has OFAC branded your company with the scarlet letter? Getting removed from the SDN list is possible, but it’s not fast, it’s not easy, and it’s not guaranteed. The primary path is a petition for administrative reconsideration filed with OFAC, arguing mistaken identity, changed circumstances, or that the original factual basis was simply wrong.You must prove it with real documented evidence. OFAC is skeptical of...

In this episode of Corruption, Crime and Compliance, Michael Volkov examines how Delaware’s Caremark doctrine has matured through a recent run of decisions involving Teligent, Regions Financial, and Boeing, all centered on the question of when a board’s failure to prevent corporate misconduct crosses from ordinary mismanagement into an actual breach of the duty of loyalty. He walks through Teligent’s officer-level oversight failures in FDA...

Are you rubbing elbows with criminals? When OFAC designates someone a specially designated national, or SDN, it’s not a warning label. It’s a legal wall. Every asset that party has anywhere in U.S. jurisdiction, or in the hands of a U.S. person, is frozen. Every U.S. person is barred from transacting with them, directly or indirectly. The trap is OFAC’s 50% rule, which means any...

In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down Veloxis Pharmaceuticals’ more than $46 million settlement with DOJ and HHS-OIG over a years-long kickback scheme involving its kidney transplant drug Envarsus XR, a scheme the DPA says was directed in part by the company’s own former CEO. He examines why Veloxis avoided prosecution and instead secured a deferred prosecution agreement under DOJ’s...

At $125 million, breaking the law can never be a cost of doing business. UBS Bank was hit with a $125 million FinCEN penalty, the largest ever against a broker-dealer under the Bank Secrecy Act. This is UBS’s second Bank Secrecy Act action in less than a decade. In 2018, regulators told UBS: fix your foreign currency wire monitoring. It never did. The same gap...

In this episode of Corruption, Crime and Compliance, Michael Volkov examines L3Harris Technologies’ abrupt ouster of chairman and CEO Christopher Kubasik over a code-of-conduct violation, and why the story is really a board governance cautionary tale rather than a typical enforcement matter. He traces Kubasik’s earlier, similar departure from Lockheed Martin in 2012 alongside comparable cases involving Brian Krzanich at Intel and Mark Hurd at...