Is your routine payment actually a bribe? Scolar, an Omaha agricultural company, resolved an FCPA case for over $10 million after using customs brokers to bribe Mexican officials, about $2,000 for each train that crossed the border. It was invoiced as reinspection fees paid routinely for six years. Nobody asked what the money actually bought. Stop treating customs brokers, freight forwarders, and logistics providers like...
In this episode of Corruption, Crime and Compliance, Michael Volkov makes the case that every organization needs a written AI Acceptable Use Policy now, not eventually, because employees are already using AI tools with or without formal governance. He walks through the three core risk categories driving that urgency: confidentiality exposure when employees submit sensitive data to ungoverned tools, hallucination risk from AI-generated content that...
Have you heard about the Goldman Sachs banker who bribed his way to a conviction? A federal jury in Brooklyn last week convicted Asante Berko, a former Goldman Sachs executive, on FCPA conspiracy, a substantive FCPA violation, and money laundering conspiracy. Berko managed a deal between a Turkish energy company and the government of Ghana to build a new power plant in Ghana. To win...
If you think your company can smuggle and fly under the radar screen, think again. When your company touches imports, customs, or tariffs, you need to know this. The Justice Department stood up a dedicated trade fraud task force in August of last year. Its first settlement came three months later. This past May, it delivered the largest customs-related False Claims Act recovery ever: $550...
In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down the State Department’s $36 million settlement with BAE Systems, Inc. over more than 100 alleged violations of the International Traffic in Arms Regulations and Arms Export Control Act spanning 2019 through March 2025, including unlicensed technical data exports to China, Canada, the U.K., and Germany, unauthorized defense services in Italy, France, and Indonesia,...
You think you can cheat the government? The False Claims Act says you’ll pay for it three times. The 2026 False Claims Act mid-year numbers are out, and the story is clear. DOJ isn’t backing down. It’s leaning in. DOJ is using the False Claims Act (FCA) to drive administration policy priorities. In the first half of this year alone, it notched first-ever settlements in...
In this episode of Corruption, Crime and Compliance, Michael Volkov examines the compliance risks lurking in ordinary U.S.-Mexico cross-border trade, explaining how the plaza system allows cartels to function as a de facto taxing authority over certain border corridors, extracting piso payments from legitimate commercial shipments that pass through their territory, often through customs brokers and logistics providers who absorb and disguise the cost as...
When using AI in your internal investigation, make sure you protect the attorney-client privilege. A lot of investigators are feeding interview notes, documents, even witness statements into AI tools to help organize an investigation. That’s convenient, for sure, but ask yourself: where does that data go? Is that platform actually covered by your privilege log? Did outside counsel direct that use, or did an investigator...
In this episode of Corruption, Crime and Compliance, Michael Volkov explains why forced labor compliance has shifted from a sustainability afterthought into a direct financial and operational threat. He walks through the U.S. Trade Representative’s new two-tier Section 301 tariff structure targeting 60 trading partner economies over forced labor practices, the rebuttable presumption under the Uyghur Forced Labor Prevention Act that can freeze finished goods...
When you’re conducting an internal investigation and using AI as a tool, you’re risking the use of a shifty informant. Let’s talk about a risk that I’m seeing firsthand in internal investigations: AI hallucination. I use AI in my own practice, and I got scared very quickly because it cited cases that don’t exist. It cited them confidently, persuasively, like it was reading straight off...
