Some third parties create real legal risks. Other third parties create reputational risk. Not all third parties are the same. One of the most important concepts in modern third-party risk management is distinguishing between acting vendors and incidental vendors. An acting vendor performs services on your behalf. Think customer service providers, recruiters, customs brokers, distributors, and payment processors. When these vendors use AI or engage...
In this episode of Corruption, Crime and Compliance, Michael Volkov sits down with Dan Greenberg, founder of Greenberg Corporate Intelligence, to unpack how due diligence and corporate investigations have evolved over Dan’s fifteen-plus years in the field. They cover the uneven state of corporate transparency worldwide, from the UK’s Companies House registry to persistent secrecy havens in the BVI, Cayman Islands, and even certain U.S....
When it comes to foreign bribery, borders provide no protection. The European Union just approved one of the most significant anti-corruption initiatives in decades, and multinational companies have to pay attention. The EU’s Anti-Corruption Directive is designed to harmonize anti-corruption enforcement across the member states. It expands corruption offenses, strengthens enforcement tools, and increases accountability for both individuals and organizations. Companies operating in Europe can...
How many red flags is your company missing? We’ve seen this pattern repeatedly. A third-party red flag appears. No one knows who owns the escalation process. Business pressure overrides compliance concerns. Documentation is incomplete. Monitoring never occurs. When the regulators arrive, the company can’t demonstrate effective oversight. The problem is not simply the underlying misconduct. The problem is the inability to prove that the company...
Government corruption is often viewed as a political problem, but its consequences extend far beyond government institutions. Corruption distorts economies, undermines democratic legitimacy, destroys public trust, and weakens the social fabric upon which civil society depends. In this episode, Michael Volkov explores the full impact of corruption across economic, political, and social dimensions and explains why anti-corruption compliance efforts represent far more than regulatory risk...
If your third-party risk management program uses annual questionnaires and spreadsheets, your program is already obsolete. The third-party risk environment has fundamentally changed. It used to focus on financial stability, insurance, and basic due diligence. Today, your vendors create exposures to AI risks, cybersecurity threats, sanctions violations, privacy failures, supply chain disruptions, and regulatory enforcement. Regulators are no longer asking whether you have a third-party...
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the UK’s Office of Financial Sanctions Implementation (OFSI) recently issued joint guidance comparing their respective sanctions regimes. While the document provides a useful overview of similarities and differences, it also sends a much broader message: international sanctions enforcement is becoming increasingly coordinated. In this episode, Michael Volkov examines why multinational companies should move beyond...
Many companies carefully review each and every vendor. Almost none review their vendor’s vendor. This creates one of the biggest blind spots in modern risk management. Your payroll vendor may use a third-party AI provider. Your software company may rely on multiple subcontractors. Your logistics provider may depend on dozens of suppliers across the globe. Every one of these relationships creates additional risk. Cybercriminals are...
Bosch agreed to pay more than $43 million in penalties and disgorgement for illegally exporting products and software to Huawei in violation of U.S. export control laws, while simultaneously receiving the first declination issued under DOJ’s revised National Security Division Corporate Enforcement Policy. In this episode, Michael Volkov examines the enforcement action, the compliance failures that led Bosch to misunderstand and misapply the Foreign Direct...
When it comes to third-party vendors, what you don’t know is hurting you. Third parties rely on AI for customer service, recruiting, compliance screening, marketing, and decision-making. But when a third party uses AI, your organization is on the hook for legal, regulatory, contractual, and reputational risks. Organizations need to understand which third parties use AI, what tools they use, what data is being shared,...
