Call me an optimist — it is a much better alternative than being a pessimist or a “realist” with a pessimistic bent. So, let’s start by acknowledging the obvious. Businesses are operating in a volatile environment. The...more
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...more
LRN’s Program Effectiveness Report is an important annual event. LRN consistently provides important trend, benchmarking and program measurements. As an important leader in this area, LRN never pulls any punches. This...more
5/6/2025
/ Artificial Intelligence ,
Chief Compliance Officers ,
Compliance ,
Corporate Culture ,
Corporate Governance ,
Due Diligence ,
Emerging Technologies ,
Employee Training ,
Ethics ,
Generation Z ,
Risk Management ,
Third-Party Risk
The Justice Department’s six-month pause on FCPA enforcement has left a gap in the global anti-corruption fight. The Justice Department played a critical role in coordinating international efforts and enforcement. in the...more
4/29/2025
/ Anti-Corruption ,
Bribery ,
California ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
Government Agencies ,
Switzerland ,
UK
Could your routine data transfers now violate federal law? The DOJ’s new Data Security Program (DSP) targets the flow of U.S. sensitive personal and government data to foreign adversaries — and the clock is ticking. In this...more
As if legal and compliance professionals had enough responsibilities on their plates, DOJ dropped another shoe (to join the tariffs, sanctions and export controls, and immigration issues) and upped the stakes for ethics and...more
4/25/2025
/ Audits ,
Compliance ,
Data Privacy ,
Data Security ,
Deadlines ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement ,
New Regulations ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management
How prepared is your organization to handle the evolving landscape of sanctions compliance? In this episode of Corruption, Crime and Compliance, Michael Volkov dives into critical sanctions compliance cases and their...more
Many “good government” initiatives continue to be enacted or implemented on Capitol Hill or in the Executive Branch — notwithstanding changes in political control. While working on Capitol Hill, the bulk of the legislative...more
4/18/2025
/ Compliance ,
Data Privacy ,
Data Security ,
Department of Justice (DOJ) ,
Executive Orders ,
Export Controls ,
National Security ,
New Regulations ,
Personal Data ,
Prohibited Transactions ,
Regulatory Requirements ,
Sensitive Personal Information
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
For compliance officers, this is a stressful time. How is that for another profound grasp of the obvious? Most compliance officers face a well-known assortment of risks — bribery, trade, False Claims Act, data privacy,...more
Chief compliance officers are adjusting a new, risk world, where top risks include export controls, sanctions, and immigration enforcement. At the same time, some risks remain — third-party risks, conflict of interest, fair...more
3/25/2025
/ Chief Compliance Officers ,
Compliance ,
Department of Justice (DOJ) ,
Export Controls ,
Imports ,
International Trade ,
Regulatory Requirements ,
Risk Assessment ,
Risk Management ,
Tariffs ,
Third-Party Risk ,
Trump Administration
When assessing your third-party risks, it is important to start with one important division — a company’s supply chain and on the flip side, a company’s distribution chain. Sourcing materials and supply chain links present a...more
3/19/2025
/ Anti-Corruption ,
Anti-Money Laundering ,
Cartels ,
Compliance ,
Department of Justice (DOJ) ,
Distributors ,
Due Diligence ,
Financial Crimes ,
Human Trafficking ,
Risk Management ,
Supply Chain
We have some new vernacular to bring into the compliance arena — companies need to address risks of interacting with cartels and transnational criminal organizations (TCOs). Companies need to understand the laws used to...more
2/25/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Cartels ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Financial Institutions ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
SDN List ,
Supply Chain
The scope of new import tariffs and regulations portends significant operational risks and disruptions. It is easy to imagine numerous companies that depend on imports for production purposes are facing a new set of...more
2/20/2025
/ Anti-Dumping Duty ,
Canada ,
China ,
Compliance ,
Customs and Border Protection ,
Exports ,
Imports ,
Mexico ,
Regulatory Reform ,
Risk Management ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trade Policy ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
We live in a topsy-turvy world. This is an exaggeration but sets up my points in this blog post. We are now seeing the shuffling of corporate risks and every board, C-Suite and legal, compliance and risk management team has...more
2/18/2025
/ Anti-Corruption ,
Antitrust Division ,
Competition ,
Compliance ,
Department of Justice (DOJ) ,
Diversity and Inclusion Standards (D&I) ,
Foreign Corrupt Practices Act (FCPA) ,
Human Resources Professionals ,
Immigration Enforcement ,
International Trade ,
Risk Assessment ,
Risk Management ,
Trump Administration
The dust is settling and for all the drama surrounding the Trump Administration’s refocus on FCPA enforcement, the picture is becoming a little bit clearer. When cooler heads prevail, it is much easier to pick through the...more
2/14/2025
/ Anti-Corruption ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Diversity and Inclusion Standards (D&I) ,
Enforcement Actions ,
Executive Orders ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Agenda ,
Regulatory Reform ,
Trump Administration
What an amazing turn of events? — Who would have predicted that the Trump Administration would take such a bold action in the name of advancing “American Competitiveness.” I admit I did not see this coming — the Trump...more
2/12/2025
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Enforcement ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Regulatory Agenda ,
Trump Administration
In an unprecedented action, the Trump Administration pushed the button and ended FCPA enforcement, at least for 180 days, until new guidance is issued by the Department of Justice. The White House’s announcement seemed to...more
Family International, a Florida real estate company, and its U.S. owner, Roman Sinyavsky, settled with OFAC for $1.07 million for 73 violations of the Russia Sanctions program. In a separate criminal case, Roman Sinyavsky...more
2/5/2025
/ Compliance ,
Corporate Misconduct ,
Criminal Prosecution ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Fines ,
Fraud ,
Guilty Pleas ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
White Collar Crimes
When evaluating AI risks, legal, ethics and compliance professionals need to divide the question into two — first, what are risks from legal, ethics and compliance internal use of AI? and second, what are business risks from...more
1/31/2025
/ Artificial Intelligence ,
Compliance ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Ethics ,
Intellectual Property Protection ,
Policies and Procedures ,
Risk Management ,
Risk Mitigation
Not to sound like a broken record — but we are consistently asking the compliance community the same question. As far back as March 2013, on this very blog, I wrote a posting — The Future of Compliance — What Will the New...more
In 2017, when President Trump first took office, big changes were expected in FCPA enforcement. Much of this reflected President Trump’s expressed misgivings on the substance of the FCPA. He was not a big fan of the law and...more
1/28/2025
/ Anti-Corruption ,
Compliance ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
U.S. Treasury
Can the DOJ’s commitment to holding individuals and corporations accountable under the FCPA survive the changing political climate in 2025?
Will the push for innovation in corporate compliance programs be enough to maintain...more
Córdoba Music Group LLC (Córdoba), a manufacturer of musical instruments based in California, has agreed to pay $41,591 to settle its civil liability for violations of sanctions on Iran. On nine occasions, Córdoba shipped...more
1/24/2025
/ Civil Monetary Penalty ,
Compliance ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
International Trade ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Risk Management ,
Sanction Violations ,
US Trade Policies ,
Voluntary Disclosure
OFAC means what it says — in more ways than one. In a precedent setting case, OFAC brought its first enforcement action against an individual for violating the Global Magnitsky Sanctions Regulations....more
1/23/2025
/ Anti-Corruption ,
Blocked Person ,
Compliance ,
Economic Sanctions ,
Enforcement Actions ,
Financial Services Industry ,
Financial Transactions ,
Global Magnitsky Act ,
Human Rights ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Sanctions ,
SDN List ,
Settlement ,
Statutory Violations ,
U.S. Treasury ,
White Collar Crimes