I was honored to appear on The Third Party Risk Association’s Podcast, TPRM Exchange, hosted by Hilary Jewhurst, to have an interesting discussion on Sanctions Compliance. The podcast is available HERE.
Michael Peregrine and Ashley Hoff recently published an interesting article on the importance of Board Vigilance on Corporate Fraud — a copy of this insightful article is available below.
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...
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...
FinCEN’s $125 million penalty against UBS is notable for more than its size, though it is the largest fine ever imposed on a broker-dealer under the Bank Secrecy Act. What makes this case a critical study for compliance officers is that it is a recidivism case. UBS was fined for Bank Secrecy Act violations in 2018, and according to FinCEN’s August 3 announcement, the bank...
A federal jury sitting in Brooklyn has convicted Asante Kwaku Berko, a dual U.S.-Ghanaian citizen and former Executive Director in Goldman Sachs’ Investment Banking Division, on charges of conspiracy to violate the Foreign Corrupt Practices Act, a substantive FCPA violation, and money laundering conspiracy, following a nine-day trial. Berko later went on to serve as Managing Director of Tema Oil Refinery, one of Ghana’s major...
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...
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...
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...
A significant shift in U.S. enforcement policy is underway, and most companies operating in Mexico, Brazil, and elsewhere in Latin America have not yet fully absorbed what it means for them. Over the past year and a half, the government has moved major cartels and organized criminal networks onto the same legal footing as international terrorist organizations. That reclassification is not a symbolic gesture. It...
