Conflicts of interest are not abstract compliance niceties. They are serious risks to integrity that, if left unidentified or unmitigated, can erode employee trust, compromise decision-making, and expose organizations to regulatory enforcement, litigation, and reputational harm. Recent high-profile scandals involving relationships between supervisors and subordinates have underscored how personal conflicts can quickly morph into enterprise-wide compliance failures when controls, oversight, and ethical culture are weak....

The Justice Department has increased False Claims Act prosecutions, reflecting a continued focus on healthcare fraud and a new initiative on trade fraud.  DOJ announced the largest annual recovery figure in the FCA’s history — $6.8 billion in settlements and recoveries.  FCA whistleblowers filed a record number of new cases — 1,297 lawsuits and the government initiated 401 investigations.  Since 1986, DOJ has recovered a...

The compliance industry appears to be taken over by AI-this and AI-that.  Third party risk bleeds into major AI risks, corporate governance needs to incorporate AI risks, and policies and procedures have to incorporate AI risks, while of course no risk assessment is worth its sale unless there is a discussion of dramatic AI risks. My first response is whoa — let’s all take a...

The most significant compliance and enforcement issue remains trade enforcement — sanctions and export controls.  In the second posting, I want to focus on the new and interesting development in this area: the use of the False Claims Act to capture violations of tariffs and customs duties. With all the hype on the trade compliance front, when you calculate the numbers relating to criminal enforcement,...

Scott Greytak, Transparency International, and Nate Sibley, Hudson Institute, join Michael Volkov for an interesting discussion reviewing anti-corruption issues and trends for the upcoming year.

Tom Fox joins Michael Volkov to discuss ethics and compliance issues for the year 2025. Tom and Mike focus on the importance of ethics, conflict of interest, trade compliance, organizational justice and other issues. This is Part 2 of a 2-Part Episode.

Tom Fox joins Michael Volkov to discuss ethics and compliance issues for the year 2025. Tom and Mike focus on the importance of ethics, conflict of interest, trade compliance, organizational justice and other issues. This is Part 1 of a 2-Part episode.

What do you do when the headlines shift faster than your risk matrix can keep up? In this episode, Michael Volkov dives into the challenge of adapting compliance programs in the face of volatile and fast-changing global risks—from tariffs and trade controls to supply chain disruptions and third-party exposures. While the pressure to react is constant, the real key is staying anchored in your company’s...

With the beginning of the aggressive trade enforcement era, companies need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important. As we embark on a new criminal enforcement era surrounding sanctions violations, companies have to address this issue and do it correctly. In this episode, Michael Volkov takes a comprehensive look at third-party risks from the distribution...

Is the DOJ really changing its playbook on FCPA enforcement, or is it business as usual under a new administration? In this episode, Michael digs into two headline developments that say a lot about where things are headed – the first FCPA declination under the Trump Administration and the first indictment. Both shed light on how DOJ is applying its policies in practice, what companies...