I have written extensively on the importance of trade compliance. The risk landscape has changed rapidly with the Russia-Ukraine war, the Trump Administration’s focus on tariffs, economic nationalism, and sanctions and export...more
10/6/2025
/ Economic Sanctions ,
Export Controls ,
International Trade ,
Regulatory Requirements ,
Risk Management ,
Russia ,
Sanctions ,
Supply Chain ,
Sustainability ,
Tariffs ,
Trade Policy ,
Trump Administration ,
Ukraine ,
World Economic Forum
You can always count on LRN as a consistent source of important ethics and compliance program trends and insights. In its latest report, LRN provided important insights on company Codes of Conduct. The last report from LRN on...more
Like the annual Presidential State of the Union Address, NAVEX’s yearly State of Risk and Compliance Report provides important insights and benchmarks against which compliance professionals can measure their own...more
9/30/2025
/ Artificial Intelligence ,
Board of Directors ,
Compliance ,
Corporate Governance ,
Due Diligence ,
Ethics ,
Internal Investigations ,
RegTech ,
Risk Assessment ,
Risk Management ,
Technology ,
Third-Party ,
Training ,
Whistleblowers
Compliance has its lingo — and one particular one I like, Third-Party Risk Management or “TPRM.” Years ago, everyone cited third-party risks. Now, we use TPRM as if everyone knows exactly what it stands for. The language...more
9/18/2025
/ Anti-Corruption ,
Artificial Intelligence ,
Cybersecurity ,
Data Privacy ,
Due Diligence ,
Economic Sanctions ,
Foreign Corrupt Practices Act (FCPA) ,
General Data Protection Regulation (GDPR) ,
Risk Assessment ,
Risk Management ,
Sanctions ,
Supply Chain ,
Third-Party ,
Third-Party Risk
The Trump Justice Department has fully embraced the False Claims Act, stretching its use to include trade enforcement. DOJ recognizes the power of the FCA, the issues at stake, and the ability to extract large settlements....more
9/12/2025
/ Anti-Dumping Duty ,
Countervailing Duties ,
Customs ,
Department of Justice (DOJ) ,
Duties ,
Enforcement Actions ,
Evasion ,
False Claims Act (FCA) ,
Importers ,
Imports ,
International Trade ,
Voluntary Disclosure ,
Whistleblowers
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...more
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...more
9/3/2025
/ Antitrust Division ,
Antitrust Investigations ,
Big Tech ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Hart-Scott-Rodino Act ,
Leniency Programs ,
Merger Reviews ,
Mergers ,
Pharmaceutical Industry ,
Price-Fixing ,
Trump Administration
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...more
9/3/2025
/ Compliance Monitoring ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Risk Management ,
Sanction Violations ,
Sanctions ,
Supply Chain ,
Third-Party Risk
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...more
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 -...more
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...more
8/18/2025
/ AI Act ,
Artificial Intelligence ,
Compliance ,
Corporate Governance ,
EU ,
Export Controls ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
Healthcare ,
New Legislation ,
Regulatory Requirements ,
Risk Management
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...more
8/14/2025
/ Artificial Intelligence ,
Automated Decision Systems (ADS) ,
Best Practices ,
Bias ,
Board of Directors ,
Compliance ,
Data Privacy ,
Data Security ,
Governance Standards ,
Incident Response Plans ,
Policies and Procedures ,
Regulatory Requirements ,
Risk Management ,
Risk Mitigation
Well, let’s all admit it — we have all enjoyed using the new, hot technology, AI. It is an understatement to opine that AI is transforming our world, business and personal. This development compares to the 1990s and the...more
8/14/2025
/ AI Act ,
Artificial Intelligence ,
Bias ,
Data Privacy ,
Data Protection ,
Deep Fake ,
Discrimination ,
Federal Trade Commission (FTC) ,
Intellectual Property Protection ,
Regulatory Requirements ,
Risk Management ,
State Privacy Laws
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...more
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...more
What happens when a company tries to outsmart the system - and gets caught red-handed by the DOJ in a $140 million export control scheme tied to Chinese military supercomputers?
In this episode, Michael dives into the DOJ’s...more
What happens when a company tries to outsmart the system - and gets caught red-handed by the DOJ in a $140 million export control scheme tied to Chinese military supercomputers?
In this episode, Michael dives into the DOJ’s...more
Well, we are in a new era — a fundamental change has occurred, long in the making. National security and trade enforcement have coalesced to elevate trade risks — sanctions and export controls violations will be prosecuted...more
8/7/2025
/ Bureau of Industry and Security (BIS) ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Due Diligence ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
Training
Criminals are not as smart as they think they are. There is nothing so unique that elevates a scheme into the ethereal world of brilliance. The schemes get to be “typical” and the means by which they are executed are often...more
DOJ’s initiation of its aggressive trade enforcement strategy is quickly unfolding — and the new strategy is a real and significant threat to all companies engaged in international trade. We are no longer in the era of FCPA...more
8/5/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Entity List ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Intellectual Property Protection ,
International Trade ,
National Security ,
PRC ,
Risk Management ,
Semiconductors ,
Technology Sector ,
U.S. Commerce Department
NAVEX dominates the hotline market. Given its global footprint, NAVEX has access to a large database of employee reports. Building on this unique perspective, NAVEX provides an annual report analyzing the employee reporting...more
8/4/2025
/ Annual Reports ,
Benchmarking ,
Best Practices ,
Compliance ,
Corporate Governance ,
Data Collection ,
Data Privacy ,
Data Reporting ,
Hotlines ,
Incident Response Plans ,
Internal Reporting ,
Reporting Requirements ,
Risk Management ,
Whistleblower Hotlines ,
Whistleblowers
Is your internal reporting program keeping up or falling behind the curve?
With over 2.15 million reports analyzed from nearly 70 million employees worldwide, NAVEX's 2025 Regional Whistleblowing & Incident Management...more
NAVEX dominates the hotline market. Given its global footprint, NAVEX has access to a large database of employee reports. Building on this unique perspective, NAVEX provides an annual report analyzing the employee reporting...more
7/29/2025
/ Compliance ,
Corporate Governance ,
Employee Rights ,
Employment Policies ,
Ethics ,
EU ,
Internal Reporting ,
Reporting Requirements ,
Retaliation ,
Risk Management ,
Whistleblowers ,
Workplace Safety
The Trump Administration intends to leave a strong enforcement mark on fraud and trade enforcement. DOJ is linking together trade enforcement and False Claims Act cases in an unprecedented manner that will open up new...more
7/28/2025
/ Consumer Protection Laws ,
Customs ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Evasion ,
False Claims Act (FCA) ,
Fraud ,
Imports ,
International Trade ,
Investigations ,
Tariffs ,
Trade Policy ,
Trump Administration
A competitor could trigger a federal investigation against your company, just by filing a whistleblower complaint about your imports.
In this episode, Michael Volkov explores how the Trump Administration is reshaping the...more