Category: Podcasts

Episode 443 — Nothing Crosses the Border for Free

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...

Could AI Use Waive Privilege in Your Internal Investigation?

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...

Episode 442 — When Forced Labor Risk Hits the P&L

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...

Can You Trust AI During an Internal Investigation?

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...

Episode 441 — Severin Wirz on his New Book, “Bribery Beyond Borders: A History of the FCPA”

On the Corruption, Crime and Compliance podcast, host Mike interviews Severin Wirtz, an in-house compliance lawyer (now at a semiconductor company, formerly at Trace International and a law firm where he cut his teeth on the Bonny Island FCPA case) about his new book, Bribery Beyond Borders, a history of the Foreign Corrupt Practices Act that took him nearly fifteen years to research and write. Wirtz argues the...

Are You Looking for DOJ Enforcement in the Wrong Place?

If you’re looking at the Justice Department and only at FCPA cases, you’re looking in the wrong place. Everyone’s talking about the DOJ going soft on corporate crime. I want to push back on that narrative because I think it’s incomplete and, honestly, a little dangerous if compliance officers believe it. Yes, traditional FCPA and bribery prosecutions have slowed. But look at where the resources...

Episode 440 — Chris Focacci: AI, Due Diligence, and the Limits of Machine Judgment

In this episode of Corruption, Crime and Compliance, Michael Volkov sits down with Christian Focacci, founder of Threat Digital, for their annual check-in on AI’s evolving role in due diligence and compliance. Focacci traces how AI adoption has matured from early hype and generic chatbot rollouts to more disciplined, use-case-specific tooling, while cautioning that the underlying models still hallucinate and should never be treated as...

Episode 439 — The Scoular Company FCPA Resolution

In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down the Justice Department’s $10.2 million foreign bribery resolution with The Scoular Company, an Omaha-based agricultural supply chain company that used customs brokers to pay more than $400,000 in bribes to Mexican officials over six years so that contaminated grain shipments could cross the U.S.-Mexico border despite failed inspections. Volkov walks through the mechanics...

Has DOJ Enforcement Shifted Rather Than Slowed Down?

Everyone’s talking about the DOJ going soft on crime. I want to push back on that narrative because I think it’s incomplete and, honestly, a little dangerous if compliance officers believe it. Yes, traditional FCPA and bribery prosecutions have slowed, but look at where the resources actually went. Trade enforcement is exploding. Sanctions enforcement is aggressive and getting more aggressive by the month. And here’s...

Should Compliance Programs Relax When DOJ Enforcement Slows Down?

When it comes to DOJ enforcement, the pendulum swings, and it always returns. Don’t let it knock you off your feet. I’ve been watching the headlines, and so have you. Fewer corporate guilty pleas, non-prosecution agreements for Alibaba and Eagle Bank, charges dropped against Boeing and Halkbank from Turkey. The word from Main Justice is: hold individuals accountable, go easier on companies. I get why...