Corruption Crime & Compliance
Michael Volkov
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Michael Volkov discusses current and hot topics in the legal realms of corruption, crime, and compliance.
Эпизоды
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What Is the Ethics Premium? 23.07.2026 1минThe root of every strong compliance program is a strong culture.I say this on every episode, and I’m going to keep saying it. Culture is the single most important control that your compliance program builds. It’s at the heart of every compliance program—not the policy binder, not the training module. Culture.Here’s what the research really shows: companies with strong ethical cultures perform better financially. They’re more sustainable because employees believe in the mission. They don’t cut corners when nobody’s watching. And employee engagement and satisfaction go up—way up—when people trust that their company will do the right thing, even under pressure.Think about what this means practically: lower turnover, higher productivity, fewer whistleblower complaints turning into full-blown investigations because people raise issues early instead of burying them.That’s the ethics premium, and it’s real.So, if you’re a CCO fighting for budget, stop pitching compliance as a cost center. Pitch it as what it really is: the thing that makes your business more successful, more sustainable, and a place people actually want to work.Culture isn’t a soft metric. It’s your bottom line.The Ethics and Compliance Q and A show is produced by One Stone Creative. -
Episode 435 -- Inside the Mind of the CCO: Aaron Nicodemus on Compliance Trends, AI Governance, and Reporting Lines 21.07.2026 35минIn this episode of Corruption, Crime and Compliance, Michael Volkov talks with Aaron Nicodemus, editor-in-chief of Compliance Week, about the state of the compliance profession and the findings of Compliance Week's latest "Inside the Mind of the CCO" survey. They discuss a troubling reversal in reporting lines, with more compliance officers now reporting through general counsel rather than directly to CEOs or boards after several years of progress toward greater independence, and what that structural shift signals about how seriously organizations value the function amid shifting political winds and uneven federal enforcement priorities. The conversation turns to artificial intelligence as both the defining opportunity and risk of the moment: survey data shows AI use across organizations has jumped to roughly 85%, yet a significant share of compliance officers report no governance plan is in place, leaving gaps around data privacy, algorithmic decision-making, hallucinated outputs, and "shadow AI" used by employees and third-party vendors alike. Nicodemus and Volkov agree that compliance is uniquely positioned to build the guardrails that let organizations use AI productively rather than recklessly, and they close by identifying data privacy, third-party risk management, and responsible AI adoption as the three pillars compliance officers should be watching most closely in the years ahead. -
Which Vendors Create the Most Risk? 21.07.2026 1минSome 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 misconduct, liability flows to your company.Incidental vendors present a different risk profile.Their primary exposure may be reputational rather than direct legal liability.This distinction is critical and allows companies to focus their resources where they matter most when it comes to mitigating risk.The Ethics and Compliance Q and A show is produced by One Stone Creative. -
Episode 434 -- Due Diligence in the Age of AI: A Conversation with Dan Greenberg 19.07.2026 33минIn 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. states, and discuss how generative AI now lets fraudsters build convincing fake websites, executive bios, and LinkedIn profiles with minimal effort, raising the bar for investigators who must verify rather than trust what they find online. Dan walks through his three-bucket approach to gathering intelligence (traditional public records, advanced open-source and social media analysis, and human sources), and the conversation turns to the unique challenges of investigating counterparties tied to China and Russia, where nuance and thoroughness are essential to avoid overbroad assumptions. The episode closes on a practical note for compliance professionals: as supply chain, sanctions, trade, cybersecurity, and AI-vendor risks pile onto traditional FCPA-driven due diligence, resolving red flags and documenting the process remain the non-negotiable foundations of an effective program. -
Foreign Bribery Has No Borders 16.07.2026 1минWhen 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 expect greater scrutiny of gifts, hospitality, conflicts of interest, influence peddling, and bribery schemes.The overall message is clear.Europe is moving toward a more aggressive and coordinated anti-corruption enforcement system.The Ethics and Compliance Q and A show is produced by One Stone Creative. -
How Many Red Flags Are You Missing? 14.07.2026 1минHow 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 exercised reasonable oversight.Enforcement agencies punish misconduct, but they often punish weak governance even more.The Ethics and Compliance Q and A show is produced by One Stone Creative. -
Episode 433 -- The Corruption Reckoning: How Government Corruption Destroys Economies, Democracies, and Societies 12.07.2026 7минGovernment 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 management. They are essential tools in defending the institutions and values that support free markets, democracy, and the rule of law. -
Regulators Want Proof It Works 09.07.2026 1минIf 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 risk program.They're asking whether your program actually works.Annual reviews are no longer enough.Risks change daily.Vendors deploy new AI tools. Ownership changes. Sanctions risks emerge overnight.The future belongs to those companies that embrace continuous monitoring, automated screening, and dynamic risk management.The Ethics and Compliance Q and A show is produced by One Stone Creative. -
Episode 432 -- OFAC and OFSI Send a Clear Message: Global Sanctions Compliance Has Entered a New Era 08.07.2026 6минThe 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 country-by-country compliance programs and build integrated, enterprise-wide sanctions compliance frameworks. He discusses key differences involving ownership and control, reporting obligations, voluntary disclosures, and strict liability standards, while offering practical recommendations for strengthening global sanctions compliance. As always, the discussion emphasizes practical solutions, ethical leadership, and building compliance programs that work in the real world—because effective compliance is more than following rules; it's earning trust and protecting enterprise value. -
Your Vendors Have Vendors 07.07.2026 1минMany 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 exploiting fourth-party relationships to gain access to enterprise systems.Regulators are paying attention as well.You need to turn your attention to your vendors' vendors.The Ethics and Compliance Q and A show is produced by One Stone Creative. -
Episode 431 -- Bosch Pays $43 Million for Illegal Huawei Exports 05.07.2026 7минBosch 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 Product Rule, the warning signs the company failed to recognize, and the lessons organizations can learn about export controls compliance, compliance staffing, escalation procedures, and risk management. The episode also highlights the significant benefits of voluntary self-disclosure, cooperation, and remediation in reducing criminal enforcement risk in today's increasingly aggressive national security enforcement environment. -
Who Owns Third-Party AI Risk? 02.07.2026 1минWhen 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, what controls exist, and who is responsible when something inevitably goes wrong.Third-party AI governance is a critical component of vendor management.The Ethics and Compliance Q and A show is produced by One Stone Creative. -
Episode 430 -- OFAC's Iran General License X: A Temporary License or a Fundamental Shift? 30.06.2026 8минThis episode examines OFAC’s new Iran General License X and why it may represent one of the most significant Iran sanctions developments in years. Michael Volkov explains what the license authorizes, why it matters amid ongoing diplomatic negotiations, and why companies should not mistake temporary sanctions relief for a permanent policy shift. The episode highlights practical compliance steps, including careful transaction analysis, documentation, due diligence, screening updates, and close monitoring before the license expires. As always, the focus is on practical, risk-based compliance: helping companies identify legitimate business opportunities while protecting ethics, integrity, and trust. -
5 Keys to Effective Trade Compliance (Part 2) 30.06.2026 1минNot all sanctions violations are willful.Some companies just don't know any better.An effective trade compliance program needs three critical elements.First, in addition to the two we spoke about in the last episode, organizations and companies have to monitor transactions, shipping documents, vessels, payment flows, and escalation of red flags.Employee training is critical.OFAC's compliance framework specifically identifies training as a core compliance expectation.And finally, organizations need to monitor, audit, and test whether their controls are actually working.A compliance program that is never tested is simply operating on assumptions.The best trade compliance programs don't just detect violations, they prevent them.The Ethics and Compliance Q and A show is produced by One Stone Creative. -
Episode 429 -- AI Governance Collision: Why Business and Compliance Must Stop Fighting and Start Building 29.06.2026 8минArtificial intelligence has created one of the most significant governance challenges organizations have faced in decades. Business leaders are under intense pressure to deploy AI quickly, while legal and compliance teams are warning about mounting regulatory, legal, operational, and reputational risks. In this episode, Michael Volkov explains why both sides are right, identifies the most dangerous AI governance gaps emerging across organizations today, and outlines a practical roadmap for responsible AI adoption. The message is clear: the companies that will succeed in the AI era will not be those that move fastest—they will be those that build sustainable AI programs grounded in governance, accountability, and trust. -
Episode 428 -- Michael Volkov Guest Appearance on Collin McKee's Podcast EndeavorsAI 27.06.2026 28минMost companies think they have a handle on AI. Most don't.Compliance attorney Michael Volkov has sat across the table from Fortune 500 compliance teams, major law firms, and Berkshire Hathaway subsidiaries — and what he keeps finding is "shadow AI": people using AI at work that leadership has no idea about. In this conversation with host Collin McKee, he breaks down where the real legal risk lives, how to protect your business, and why the smart move isn't to slow down — it's to deploy AI the right way.We get into:"Shadow AI" — why your team is already using it and what it exposes you toThe vendor due-diligence checklist before you sign with any AI providerWhy AI hallucinations are a liability you can be sued overHR, hiring bias, and high-risk algorithmic decisionsWriting an AI acceptable-use policy that protects you without slowing you downThe EU AI Act, litigation risk, and AI insuranceWhy you won't be replaced by AI — but by people who know how to use itA practical playbook for any business adopting AI, especially law firms and regulated industries.Chapters0:00 Why most companies don't actually have a handle on AI0:38 The CEO email that shows how NOT to deploy AI4:09 Shadow AI: a Fortune 100 example6:42 The real risk — hiring, HR & algorithmic decisions9:34 Why AI hallucinations are a legal liability10:03 The vendor due-diligence checklist before you sign12:50 Why companies still won't write an AI use policy16:24 The "double-checking wastes my time" trap18:39 The EU AI Act, litigation & AI insurance19:27 What small & mid-size businesses actually need23:39 You won't be replaced by AI — but by people who use it26:19 AI as a force multiplier, not a headcount cut28:04 Where to find Michael VolkovAbout the guest — Michael VolkovCompliance attorney and AI governance expert. Founder of The Volkov Law Group.YouTube: / @volkovlawtv Blog & podcast (Corruption, Crime & Compliance): https://blog.volkovlaw.com/LinkedIn: / michael-volkov-9716b45 About Endeavor's AIIf this episode hit home and your company needs help with implementation, automations, workflows, and the AI infrastructure to do this right — that's what we do.Website: https://www.endeavorsai.com/Book a 30-min call: https://calendly.com/collin-endeavors...Instagram: / endeavorsai LinkedIn: / endeavors-ai -
Episode 427 -- Venezuela Sanctions Update: Building the Operational Compliance Program 27.06.2026 9минMichael Volkov delivers the operational compliance program guidance companies must implement to execute safely within OFAC's new Venezuela general license framework, structured around five program pillars: transaction scoping with mandatory lifecycle revalidation at each critical deal stage; beneficial ownership-based counterparty due diligence that goes beyond standard SDN screening to identify Russia, Iran, Cuba, North Korea, and PRC-connected ownership structures; contract review and modification to incorporate mandatory U.S. governing law provisions, sanctions representations, FGDF payment mechanics clauses, and robust termination rights; pre-built Foreign Government Deposit Fund payment procedures requiring documented legal and compliance approval, a standardized State Department submission package, and advance coordination before payment deadlines arrive; and a transaction-specific reporting compliance program with calendar-tracked deadlines under GL 52, GL 46B, and GL 51B. Michael concludes that the new Venezuela framework creates genuine commercial opportunity but demands purpose-built compliance architecture—companies that proceed without it are not operating within the authorization. -
5 Keys to Effective Trade Compliance (Part 1) 25.06.2026 1минWhat separates effective trade compliance programs from ineffective ones?It starts at the top.Good, bad, or ugly, it all trickles down from the top.Here are the five keys to an effective trade compliance program.The first two are building blocks for leadership and due diligence.First, senior executives and boards must actively support trade compliance.Without leadership engagement, compliance programs become check-the-box exercises.Second, organizations need robust screening and due diligence processes.This includes customers, distributors, suppliers, beneficial owners, intermediaries, and other third parties.Trade compliance failures often begin with poor due diligence.Strong leadership and strong due diligence create the foundation for every trade compliance program.The Ethics and Compliance Q and A show is produced by One Stone Creative. -
AI Is Here. Is Governance? 23.06.2026 1минAre your employees whispering corporate secrets into the greedy ears of public-facing AI?Many organizations have no visibility into how their employees are using AI.The solution is not to ban AI.The solution is AI governance.Organizations need approved AI tools, acceptable use policies, employee training, and ongoing monitoring.The question is no longer whether your employees are using AI.The question is whether you know how they are using it.AI risk is no longer a future issue. It is a governance challenge happening right now.The Ethics and Compliance Q and A show is produced by One Stone Creative. -
Episode 426 -- Venezuela Sanctions Update: OFAC's New General Licenses and the FGDF Framework (Part 1) 22.06.2026 11минMichael Volkov examines OFAC's new Venezuela general license framework—including General License 52, General License 46B, and the newly effective General License 51B covering Venezuelan-origin minerals—analyzing how these authorizations create conditional pathways for otherwise-prohibited energy and minerals transactions while preserving the underlying blocking regime applicable to PdVSA and the Government of Venezuela. Michael explains the established U.S. entity eligibility requirement, the mandatory contractual conditions requiring U.S. governing law and U.S. dispute resolution in agreements with Venezuelan governmental counterparties, and the critical jurisdictional restrictions excluding transactions with Russia, Iran, Cuba, North Korea, and China-connected entities. The episode provides a detailed operational breakdown of the Foreign Government Deposit Fund payment mechanism established under Executive Order 14373—including the DepositorInquiries@state.gov submission process and documentary requirements—and concludes with an analysis of the multi-agency reporting obligations triggered under each applicable authorization.
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