Corruption Crime & Compliance

Christian Focacci, founder and CEO of Threat.Digital, dives into the evolving role of AI in corporate risk management. He discusses whether AI is a magical solution or merely a tool, emphasizing the necessity of human judgment in AI applications. Focacci highlights misunderstandings about large language models and the critical need for corporate AI governance. The conversation explores how AI improves due diligence processes while addressing challenges like data privacy and the balance between innovation and accountability in compliance.

Trade compliance is becoming a hotbed for federal prosecutions, as the DOJ intensifies its focus on fraud under the False Claims Act. Companies misclassifying goods or evading tariffs are now facing serious legal risks, particularly in light of national security concerns. This shift highlights the importance of robust compliance programs and the expanding role of whistleblowers. Recent multimillion-dollar settlements showcase just how quickly organizations can find themselves in the crosshairs for trade violations.

Is your company ready to bet its future on whether it can outpace a whistleblower to the DOJ’s door? In this episode, Michael Volkov takes a deep dive into the Department of Justice’s newly announced strategy to reshape corporate enforcement. With promises of greater clarity, reduced penalties, and fewer monitors, the DOJ wants companies to see voluntary disclosure as a smart and safe move - not a leap of faith. But behind the incentives lies a sharper edge: whistleblowers, shortened timelines, and a more assertive DOJ ready to move fast. Whether you’re in-house counsel, a compliance officer, or just trying to stay ahead of enforcement trends, this is a must-listen breakdown of what’s changed, why it matters, and what companies need to do now to avoid being caught off guard.You’ll hear him discuss:How companies that voluntarily disclose, cooperate, and remediate can now qualify for a declination, even with aggravating circumstancesWhy the DOJ is promising greater transparency and fairness in enforcement to reduce fear and uncertainty around self-reportingWhat changes have been made to limit when corporate monitors are imposed, and how DOJ will control their cost and scopeHow the whistleblower program has been significantly expanded to include sanctions, tariffs, trade violations, and federal program fraudWhat benefits may still be available for companies that report after DOJ has begun an investigation, including reduced fines and no monitorshipWhy DOJ is pushing prosecutors to shorten the length of corporate investigations and avoid drawn-out resolutionsWhat’s at stake if a whistleblower reports first, and how companies could lose access to key benefits by waiting too longResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group

Scott Greytak, the Director of Advocacy for Transparency International U.S., joins Josh Birenbaum, Deputy Director of FDD’s Center on Economic and Financial Power, to dive into the implications of the U.S. halting Foreign Corrupt Practices Act enforcement. Their conversation reveals how this pause has altered the anti-corruption landscape and why companies must remain committed to compliance. They also dissect the Corporate Transparency Act's changes and argue that transparency is vital for economic and national security—essentially a safeguard against global corruption threats.

What if your next import shipment becomes the centre of a federal enforcement action — not because of criminal intent, but because of a mistake? In today’s episode, Michael Volkov breaks down the expanding power and reach of U.S. Customs and Border Protection (CPB) and what it means for businesses navigating an increasingly aggressive trade enforcement landscape. With the Trump Administration’s re-defined objective of fair trade, companies across all sectors need to brace for scrutiny, adapt to evolving risks, and rethink their compliance strategies.You’ll hear him discuss:The Trump Administration’s focus on fair trade and why CPB has become a central enforcement agency under this new agendaHow CPB exercises its authority to impose regulatory penalties, seize goods, and refer serious cases for civil or criminal prosecutionThe legal standards that determine the severity of violations — fraud, gross negligence, or negligence — and how each carries different penalty thresholdsWhy the materiality of a false statement or omission is a key factor in determining whether a violation has occurredThe importance of voluntary disclosure and how it can significantly reduce potential penalties and protect company reputationThe step-by-step process of CPB administrative enforcement, including investigations, pre-penalty notices, appeals, and mitigation optionsThe expanding impact of the Enforce and Protect Act (EAPA), and how companies can be held accountable for evading anti-dumping and countervailing dutiesWhy businesses must now take a closer look at their import documentation, supply chain practices, and overall trade compliance postureResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group

Are you running a compliance program that’s making a real impact—or just checking the boxes? In this episode, Michael Volkov dives into LRN’s 2025 Program Effectiveness Report, an annual benchmark that separates the truly impactful compliance programs from those that are merely operational. Based on insights from 1,500 global ethics and compliance professionals, this year’s report draws a clear line between high-impact and medium-impact programs—and what it takes to bridge the gap. The conversation highlights urgent risks, cultural disconnects, and the strategic value of automation, data, and leadership alignment in shaping tomorrow’s compliance functions.You’ll hear him discuss:How high-impact programs are defined by their strategic use of automation, data analytics, and benchmarking tools to drive measurable compliance outcomesWhy third-party risk management—including due diligence and supply chain oversight—is a defining trait of the most effective programs todayThe growing trust gap between Gen Z employees and middle managers, and why this generational shift poses a cultural red flagThe continued dominance of outdated internal systems, regulatory complexity, and budget pressure as top operational challenges facing compliance leadersHow high-impact programs are integrating AI into both their codes of conduct and employee training, preparing teams for emerging tech risksWhat medium-impact programs can do to evolve: focus on training, automation, and peer collaboration to elevate impact and resilienceResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group

When The United States has hit pause on Foreign Corrupt Practices Act (FCPA) enforcement—it left many asking whether Europe will now be stepping up to lead the global anti-corruption charge. In this episode of Corruption, Crime and Compliance, Michael Volkov explores how European prosecutors are responding to the enforcement gap, why multinational companies can’t afford to slow down their compliance efforts, and how both state-level and international initiatives are reshaping the future of anti-bribery law.You’ll hear him talk about:The launch of a new International Anti-Corruption Prosecutorial Task Force formed by the UK, France, and Switzerland, designed to intensify cross-border enforcement and cooperation in bribery and corruption cases.The task force’s formation as a direct response to the U.S. enforcement pause, signaling that European agencies are prepared to take a more prominent role in prosecuting international corruption, especially involving multinational corporations.California’s bold move to pursue foreign bribery under its Unfair Competition Law (UCL), reinforcing that FCPA violations remain prosecutable at the state level despite federal hesitation.A continued commitment by global companies to maintain strong compliance programs, reflecting awareness that international and local enforcement can still pose serious legal and financial risks.The unexpected dismissal of the long-running FCPA case against Cognizant executives, contrasted with the DOJ's decision to move forward with prosecutions in other high-profile cases, suggesting a selective enforcement pattern under current policy shifts.A landmark case by the UK Serious Fraud Office (SFO), charging a company with failure to prevent bribery—a first for the SFO to bring such a case before a jury, potentially setting a new standard for corporate liability in the UK.ResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group

The DOJ's new Data Security Program imposes strict regulations on data transfers, raising compliance stakes for businesses. It identifies key national security concerns, defining what constitutes a 'covered data transaction.' Companies must navigate restrictions related to sensitive data, including biometric and financial information. With a focus on countries of concern, the program highlights outright prohibitions on data brokerage. U.S. firms have a 90-day window to assess vendors and update compliance systems before the impending deadline. This is a crucial time for data management!

Explore the crucial world of sanctions compliance and the lessons learned from notable cases. A staggering settlement against British American Tobacco highlights the evolution of corporate prosecutions. Epsilon Electronics illustrates the dire responsibilities companies face with third-party distributors. ELF Cosmetics reminds us of the risks tied to sourcing materials from prohibited nations. This discussion reveals the growing scrutiny on multinational corporations and emphasizes the need for robust compliance programs to navigate the changing landscape.

In a rapidly changing risk landscape, compliance programs must evolve swiftly. The importance of corporate culture as a defense mechanism is emphasized, along with quick-turn risk assessments to identify emerging threats. The podcast delves into the complexities of sanctions, particularly regarding Russia and Ukraine, and discusses indirect exposure through third parties. It also highlights the growing enforcement of tariffs and export controls, urging companies to recalibrate their strategies to avoid penalties and ensure compliance.