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...

The Trump Administration’s handling of antitrust enforcement issues is generally viewed as a wild-card — meaning there are issues of concern or focus that may not fit the “traditional” antitrust enforcement model. Depending on the issue and the players, DOJ’s antitrust interest may surprise various practitioners and commentators. Trump’s nomination of Gail Slater as DOJ’s Assistant Attorney General for the Antitrust Division was universally praised...

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...

With all of the hoopla and hysteria focused on AI and information systems, Threat.Digital, a long-time affiliate of The Volkov Law Group, Chris Focacci, CEO of Threat Digital, is a technology leader.  Chris has the ability to explain practical application of AI technology, due diligence and information systems.  He is a terrific resource and I urge all interested parties to reach out and speak with...

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...

Given the real and significant potential benefits of AI, companies have to be careful in the rush to implement AI technology.  Starting with a clear use case, companies have to weigh the potential benefits of AI technology and identify the legal and compliance risks.  An AI compliance program is a critical element of a corporate governance structure.  Building on this specific policy, companies need to...

The new world of AI presents significant benefits and risks that need to be addressed in an overall governance framework.  Luckily, the principles to apply here will surprise no one — governance, compliance, legal and risk professionals will quickly adapt well-known principles to the new frontier of AI. Starting at the Board level, AI oversight responsibility should be assigned a dedicated board committee, such as...

In the first FCPA declination under the Trump Administration, Liberty Mutual Insurance Company paid $4.7 million in disgorgement and received a declination letter from the Department of Justice. The declination reflects consistent application of the existing Corporate Enforcement Policy.  While DOJ has issued new guidance on FCPA enforcement reflecting its revised priorities, DOJ’s declination does not reference or incorporate any ideas from the guidance.  Instead,...

Last week, the Justice Department announced that Cadence Design Systems Inc. (Cadence), a global electronic design automation (EDA) technology company based in San Jose, California, agreed to plead guilty to a conspiracy to violate export control laws by selling EDA hardware, software, and semiconductor design intellectual property (IP) technology to the National University of Defense Technology (NUDT). NUDT, which is a university in the People’s...