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Corruption Crime & Compliance

Corruption Crime & Compliance

Hosted by Michael Volkov

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Episodes

470

Latest episode

Aug 2026

Language

EN

About the show

Michael Volkov tackles the current and hot topics in the legal realms of corruption, crime, and compliance.

Listen to episodes

60 recent
August 13, 20261 min

Can You Trust AI During an Internal Investigation?

When you’re conducting an internal investigation and using AI as a tool, you’re risking the use of a shifty informant.Let’s talk about a risk that I’m seeing firsthand in internal investigations: AI hallucination.I use AI in my own practice, and I got scared very quickly because it cited cases that don’t exist. It cited them confidently, persuasively, like it was reading straight off a court docket. It wasn’t.Now imagine that inside an internal investigation. You’re using an AI tool to summarise witness interviews, to search a document universe, to draft findings for audit committees.If that tool fabricates a fact, misattributes a quote, or invents a document that was never produced and nobody catches it, that error doesn’t stay contained.It becomes your investigative record. It becomes the basis for a disciplinary decision, a self-disclosure to a regulator, maybe even a certification to the government that your findings are accurate.Here’s the rule I put in place today: every AI-assisted output in an investigation gets independently verified against the underlying source material.Not spot-checked. Verified.Because the day you rely on an AI summary you never checked is the day that your investigation’s credibility, and maybe your own, is on the line.The Ethics and Compliance Q and A show is produced by One Stone Creative.

August 12, 202653 min

Episode 441 -- Severin Wirz on his New Book, "Bribery Beyond Borders: A History of the FCPA"

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 FCPA is usually reduced to a footnote of Watergate, when in fact it emerged from decades of prior anti-bribery legal tradition, Cold War fears that corrupt American multinationals (like ITT in Chile) were undermining democracy and fueling Soviet propaganda, and a narrow, contingent political path through Congress — driven by figures like Senator Frank Church, SEC enforcement chief Stanley Sporkin (who leaked findings to Congress after being blocked by Kissinger's State Department), and later William Proxmire, with Ford and even Carter only lukewarm supporters until the "Watergate babies" swept into Congress. The conversation moves to today's landscape: the Trump administration's 2025 pause on FCPA enforcement, the DOJ's new "national interest" enforcement standard, debate over prosecuting foreign officials who receive bribes (Wirtz is wary of the precedent), the emerging cartel-linked corruption cases like the Mexican Vitol/Scolar-type matter, and Wirtz's view that the statute is at an "inflection point" moving from a post-Cold War globalist rationale toward a new argument centered on fair competition and America's geopolitical brand versus China. Both agree corruption concerns are cyclical and likely to resurface domestically before circling back to FCPA enforcement. The book is available through Corporate Compliance Insights (publisher) and major retailers.

August 11, 20261 min

Are You Looking for DOJ Enforcement in the Wrong Place?

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 are actually going.Trade enforcement is exploding. Sanctions enforcement is aggressive and getting more aggressive by the month.And here’s the one that should really get your attention: the False Claims Act is now being used against companies for tariff circumvention and customs fraud, with qui tam relators and lawyers lining up to bring those cases.This isn’t a retreat. It’s a reallocation.DOJ has simply moved its firepower to where the current priorities sit: national security, trade, tariffs, sanctions, and export controls.If your compliance program is still built around FCPA risk and you haven’t retooled for trade and sanctions exposure, you are exposed right now, today.Update your risk assessment. This is not the moment to stand down.The Ethics and Compliance Q and A show is produced by One Stone Creative.

August 9, 202640 min

Episode 440-- Chris Focacci: AI, Due Diligence, and the Limits of Machine Judgment

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 an authoritative source rather than a reviewer of externally cited, verifiable information. The conversation covers the widespread problem of "shadow AI" use inside organizations without governance, the risks of letting AI creep into discretionary decision-making without human accountability, and emerging third-party risk questions as companies must now vet how vendors themselves are using AI. Volkov and Focacci also discuss the rapid rise of open-weight Chinese models, the regulatory patchwork forming at the state level (particularly around HR uses of AI), and the risk of regulatory capture favoring large AI incumbents over smaller innovators. The episode closes on a balanced note: AI is genuinely valuable for processing large data sets, triaging sanctions alerts, and boosting productivity, but only when paired with rigorous human oversight, clear documentation, and citations traceable back to verifiable source material.

August 6, 20261 min

Has DOJ Enforcement Shifted Rather Than Slowed Down?

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 the one that should really get your attention: the False Claims Act is now being used aggressively against companies for tariff circumvention and customs fraud, with qui tam relators lining up to bring those cases.This isn’t a retreat. It’s a reallocation.DOJ has simply moved its firepower to where the current priorities sit: trade, tariffs, sanctions, export controls, and national security.If your compliance program is still built entirely around FCPA risk and you haven’t retooled for trade and sanctions exposure, you are exposed right now, today.Update your risk assessment. This is not the moment to stand down.The Ethics and Compliance Q and A show is produced by One Stone Creative.

August 5, 202611 min

Episode 439 -- The Scoular Company FCPA Resolution

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 of the scheme, a strikingly simple pattern of $2,000 per-train payments disguised on invoices as "reinspection fees," and explains why DOJ treated the case as an aggravated national security matter after determining that some of the bribe money ultimately reached individuals tied to a border cartel, even though Scoular itself had no knowledge of that connection. The episode also unpacks how DOJ applied its Corporate Enforcement and Voluntary Self-Disclosure Policy to the resolution, distinguishing between the voluntary disclosure credit Scoular did not earn and the cooperation and remediation credit it did, resulting in a three-year deferred prosecution agreement, a 25 percent reduction off the bottom of the sentencing guidelines, and no independent monitor. Volkov closes with practical takeaways for compliance officers on managing customs brokers as high-risk third parties, testing the substance behind recurring payments, and moving quickly on voluntary disclosure decisions once potential misconduct surfaces internally.

August 4, 20261 min

Should Compliance Programs Relax When DOJ Enforcement Slows Down?

When it comes to DOJ enforcement, the pendulum swings, and it always returns. Don’t let it knock you off your feet.I’ve been watching the headlines, and so have you. Fewer corporate guilty pleas, non-prosecution agreements for Alibaba and Eagle Bank, charges dropped against Boeing and Halkbank from Turkey.The word from Main Justice is: hold individuals accountable, go easier on companies. I get why some executives are breathing a sigh of relief.But here’s my message to every compliance officer out there: do not read this as permission to relax.Enforcement priorities are cyclical. Administrations change. Statutes of limitations run long. The conduct you tolerate today under a lenient DOJ can absolutely come back across your desk in the future, with a lookback period that reaches right back to right now.And let’s not forget: non-prosecution agreements still require admissions, still require massive fines, and still require you to fix your program. They’re not a free pass. That’s a warning shot.Stay vigilant. Keep building your program like the next administration is already watching, because eventually it will be.The Ethics and Compliance Q and A show is produced by One Stone Creative.

August 2, 202619 min

Episode 438 -- The Fight to Save the Corporate Transparency Act: An Urgent Update

In this update episode of Corruption, Crime and Compliance, Michael Volkov speaks with Erica Hanichak of the FACT Coalition and Frank Russo of Modern Fortis about the current fight over the Corporate Transparency Act, the 2021 law requiring companies to report their beneficial owners to a secure Treasury Department database in order to close off the U.S.'s longstanding status as an easy jurisdiction for setting up anonymous shell companies used in money laundering, human trafficking, and fraud. Hanichak and Russo describe how the law's implementation has faced litigation and a legislative repeal push that narrowly cleared the House Financial Services Committee despite broad, bipartisan, cross-sector opposition from law enforcement groups, financial institutions, and anti-trafficking organizations, all of whom view beneficial ownership data as a foundational tool for tracing who truly finances and benefits from organized criminal networks. The conversation also flags the administration's forthcoming final rule, which reportedly would exempt more than 99.98% of the entities Congress originally intended to cover, and closes with a direct call for the compliance community to engage with lawmakers to preserve and strengthen, rather than gut, the beneficial ownership reporting framework that due diligence programs increasingly depend on.

July 30, 20261 min

Is Your Compliance Program Losing Its Seat at the Table?

Is your compliance program being demoted?Let’s talk about something that should worry every compliance officer. The stature of the profession is slipping.For years, the trend line was clear. Compliance officers moved out from under the general counsel, got direct lines of reporting to the CEO, and direct lines to the board.That mattered. It wasn’t just symbolic. It meant compliance had real influence before decisions got made, not after.Now look at the data. The latest Compliance Week survey found reporting lines are sliding back toward legal. Fewer CCOs sitting with the board, fewer with a direct line to the CEO, and compliance officers are telling us off the record that they feel pushed to the side.Here’s my worry. When you add a layer between compliance and leadership, you’re sending a message to your employees, to your regulators, to the market about how much this function actually matters to you.Don’t let that message be sent on your watch. Fight for your seat. Your organization needs it more than ever.The Ethics and Compliance Q and A show is produced by One Stone Creative.

July 30, 20268 min

Episode 437 -- Where Your CCO Reports Tells Me Everything: The Quiet Backslide in Compliance Reporting

Michael Volkov examines a troubling backslide in corporate governance: the quiet movement of chief compliance officers back under the general counsel after years of progress toward direct CEO reporting lines. Michael explains why the CCO's reporting structure is the single clearest signal a company sends about the value it places on compliance — shaping whether compliance influences business strategy at the design stage or is reduced to an after-the-fact cleanup function. He makes the case for a direct CCO reporting line to the CEO paired with a formal dotted line to the audit committee, including guaranteed executive sessions and unrestricted escalation authority, and warns that subordinating compliance to legal fosters a "mere compliance" mindset — meeting minimum legal requirements rather than building an ethical culture that drives employee retention, customer trust, and long-term business success. Michael closes with concrete action items for boards and compliance leaders, reminding listeners that regulators scrutinize CCO empowerment and that demoting compliance to save a line item is like canceling insurance to improve quarterly cash flow.

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