If a $36 million export violation comes down to whether a loading dock worker grabbed the right box, the problem isn’t the guy on the dock. BAE Systems just paid $36 million to the State Department for more than 100 export control violations. Here’s what makes this case worth your attention. DDTC didn’t find willful evasion. It found something more common and, honestly, scarier: a...

In this episode of Corruption, Crime and Compliance, Michael Volkov explains why acquiring a sanctions violation is even riskier than buying an FCPA problem: under programs like Cuba and Iran, U.S. ownership of a foreign target can itself create sanctions jurisdiction on closing day, turning previously lawful foreign business into violations overnight. Drawing on OFAC’s 2019 Framework for Compliance Commitments, which calls for compliance involvement...

A pharma CEO just found out the captain doesn’t always go down with the ship. Sometimes the ship stays afloat by handing him to DOJ. Veloxis Pharmaceuticals just paid over $46 million to resolve a kickback scheme involving its kidney transplant drug, lavish meals, resort stays, payments dressed up as consulting fees paid to doctors and pharmacies to drive prescription demand. Here’s the part that...

In this episode of Corruption, Crime and Compliance, Michael Volkov explains why OFAC’s 2019 Framework for Compliance Commitments, built on the five pillars of management commitment, risk assessment, internal controls, testing and auditing, and training, remains the essential foundation for any sanctions compliance program, while also walking through the substantial multi-agency guidance that has layered on top of it since 2023 through joint DOJ, BIS,...

Today’s version of the Trojan horse doesn’t need to sneak past your gate in the dead of night. It’s a software update to something you already let in. Second preview ahead of tomorrow’s webinar, and this one’s about a blind spot I see constantly. Most compliance officers think about shadow AI as employees going out and signing up for some random chatbot. That happens, but...

An AI tool isn’t a piece of software. It’s a locked door, and you have no idea how many people have a key. Quick preview ahead of tomorrow’s webinar on AI and third-party risk, because I want you thinking about this before we dive in. Here’s the mental shift every compliance officer needs to make: every AI tool your company adopts is a third-party vendor...

In this episode of Corruption, Crime and Compliance, Michael Volkov rounds up three major economic policy developments happening alongside Operation Economic Outcast: the State Department’s rescission of Syria’s nearly 47-year State Sponsor of Terrorism designation, opening the door to renewed trade and eased export controls; an escalating tariff war with Canada following the collapse of USMCA renewal talks, including a 50 percent tariff on roughly...

For anyone hoping a friendlier DOJ can make their old charges disappear, a federal judge just reminded us that vanishing requires his or her permission. Big development out of Brooklyn federal court. DOJ tried to drop the remaining bribery and obstruction charges against executives tied to Indian billionaire Gautam Adani. The judge said no. Judge Nicholas Garaufis ruled that Deputy AG Trent McCotter’s justification for...

In this episode of Corruption, Crime and Compliance, Michael Volkov devotes a full deep dive to Operation Economic Outcast, Treasury’s aggressive campaign to close off Iran’s remaining financial and commercial channels following the collapse of a June 2026 US-Iran memorandum of understanding. He walks through OFAC’s expansion of sectoral sanctions into aviation, digital assets, gold, shipping, and technology with no U.S. nexus required, the suspension...

If you’re planning for 2027 with 2025’s budget in mind, your compliance program is about to fall on its face. KPMG just surveyed 725 chief compliance officers, and the headline is simple: the job has fundamentally expanded, and if your 2027 plan doesn’t reflect that, you’re already behind. 75% of CCOs say cybersecurity and data privacy are top investment priorities. 77% say the same about...