Corruption Crime & Compliance

Hosted by Michael Volkov

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439

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Jun 2026

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About the show

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

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June 14, 20269 min

Episode 424 -- When the Government Pulls the Plug: Export Controls, Anthropic, and the AI Governance Crisis

Michael Volkov analyzes the Commerce Department Bureau of Industry and Security's June 12, 2026 export control directive ordering Anthropic to suspend all access to its Fable 5 and Mythos 5 AI models for any foreign national—a directive that, because Anthropic cannot segment its global user base by nationality in real time, resulted in a complete worldwide shutoff of both models for every customer. Michael places the directive in its full context: the months-long conflict between Anthropic and the Trump Administration stemming from the Pentagon's demand that Anthropic waive its contractual restrictions on the use of Claude for mass domestic surveillance and autonomous weapons, the unprecedented supply chain risk designation applied to Anthropic in March 2026, the active federal litigation challenging that designation in two courts, and the government's stated rationale that a third-party company had reported a jailbreak of Mythos. Michael examines the contested legal authority underlying the BIS directive, the compliance implications for enterprise AI users—including third-party AI operational risk, foreign-national access control requirements, and the inadequacy of existing SLA frameworks—and the fundamental AI governance gap that Friday's action exposed: the absence of a comprehensive statutory framework governing government authority to restrict commercial AI model access on national security grounds.

June 11, 20261 min

Are You Selling Compliance Wrong to Your Leadership Team?

Compliance isn't a cost, it's a business advantage.Compliance officers often make one critical mistake, they sell compliance as a legal requirement instead of a business advantage.Executive support grows when compliance leaders connect ethics to operational resilience, revenue protection, and enhancement, reputation, employee retention, and strategic growth.Successful compliance leaders use data, demonstrate value, communicate clearly, and align with business priorities.Employees then support the program when they see fairness, consistency, responsiveness, and leadership commitment.The best compliance programs are not built through fear, they are built through credibility.Ethics and compliance succeeds when leadership sees it as essential to business performance, not separate from it.The Ethics and Compliance Q and A show is produced by One Stone Creative.

June 10, 20268 min

Episode 423 -- Detangling Third-Part Legal and Reputation Risks

As artificial intelligence becomes embedded in third-party business operations, companies face a new and largely unexamined compliance challenge: when does a vendor's use of AI become your legal or reputational problem? In this episode, Michael Volkov unpacks the critical agency principle distinction at the heart of third-party AI risk — explaining how acting third parties who deploy AI on a company's behalf can create direct legal liability for the principal, drawing on the same legal framework that governs FCPA third-party liability, while incidental service providers who supply goods or services without acting on the company's behalf present a different but equally serious reputational risk. Michael also examines what robust AI-focused third-party due diligence must include, how to build a risk-tiered compliance framework that allocates resources proportionately, and why reduced legal liability is never the same as reduced risk in an environment where vendor AI controversies generate brand association damage regardless of legal culpability.

June 9, 20261 min

What Compliance Functions Should You Automate First?

If you want to give your compliance team superpowers, then give them the power of automation.If your compliance program is still operating primarily through spreadsheets, emails, and manual tracking, regulators already view your program as ineffective.Modern compliance risks move too fast for manual systems.You need to have sanction screening, third-party monitoring, transaction testing, hotline analytics, policy certifications, and training program metrics.The Justice Department evaluates whether compliance programs have access to data, testing capability, and real-time monitoring.Manual systems create blind spots, delayed escalation, inconsistent oversight. And weak documentation.Automation does not replace human judgment, it enhances it.The Ethics and Compliance Q and A show is produced by One Stone Creative.

June 7, 202610 min

Episode 422 -- Adani OFAC Settlement and Red Flag Lessons Learned

On May 18, 2026, the U.S. Treasury's Office of Foreign Assets Control (OFAC) announced that Adani Enterprises Limited (AEL), an India-based multinational, agreed to pay $275 million to settle 32 apparent violations of Iran-related sanctions — specifically for causing U.S. financial institutions to process approximately $192 million in payments for liquified petroleum gas (LPG) that originated from Iran, not from Oman or Iraq as represented by AEL's Dubai-based supplier. OFAC found the violations egregious and non-voluntarily disclosed, citing multiple red flags that AEL either missed or dismissed without adequate investigation: third-party warnings about Iranian-origin cargo, vessels routinely engaging in AIS manipulation and suspicious routing, certificates of origin bearing signs of falsification, and prices so far below market that they could only be commercially explained by Iranian sourcing. The case stands as a landmark reminder that sanctions compliance is not a box-checking exercise — companies must proactively investigate, formally document, and genuinely resolve red flags rather than accept supplier assurances at face value, and that failure to do so carries nine-figure consequences.

June 4, 20261 min

How Do Undisclosed Relationships Turn Into Major Corruption Cases?

The biggest cases of corruption and fraud often have their roots in the soil of conflicts of interest.Many major corruption cases begin with something companies initially dismiss as just a conflicts issue.Conflicts of interest though are early warning signs for fraud, bribery, procurement manipulation, favoritism, and self-dealing.Weak disclosure systems allow undisclosed relationships, hidden ownership interests, and vendor manipulation.Effective programs require annual certifications, ongoing disclosure obligations, manager accountability, and independent review processes.A conflict of interest program is not about policing relationships. It's about protecting integrity.The Ethics and Compliance Q and A show is produced by One Stone Creative.

June 3, 202610 min

Episode 421 -- The Dangers of AI Inaccuracy

Artificial intelligence tools remind us every day that they can make mistakes — but in the rush to embrace AI's extraordinary capabilities, the professional and compliance communities are not taking that warning seriously enough. In this episode, Michael Volkov draws on his own extensive experience in compliance, white-collar defense, and corporate governance to examine the real and serious dangers of AI inaccuracy in high-stakes professional environments, including fabricated case citations, misstatements of legal holdings, and conflation of regulatory frameworks that are invisible to non-experts but potentially devastating in their consequences. Michael argues that AI output must be treated as a starting point rather than a finished product, that human expert verification must be built into AI workflows as a structural requirement rather than an occasional check, and that professional responsibility standards do not diminish simply because an AI tool was involved in producing the work — making the verification imperative not just a best practice, but a professional obligation.

June 2, 20261 min

Are Your Distributors Getting You Into Sanctions Trouble?

Are you ready to navigate the risky waters of third-party pirates?Most sanctions violations do not happen because companies intentionally want to evade and violate sanctions. They happen because companies trust the wrong third party.The epsilon and elf enforcement matters, which I frequently speak about, demonstrate that companies get in trouble when they have weak distributor oversight, poor intermediary screening, inadequate beneficial ownership review, and failure to monitor diversion risks.Regulators expect companies to understand counterparties, trace payment flows, identify transshipment risks, and monitor red flags continuously.Third parties create the highest sanctions exposure because they operate beyond direct company control and visibility.If your company cannot explain exactly who your third parties are doing business with, regulators are going to find you liable.The Ethics and Compliance Q and A show is produced by One Stone Creative.

June 1, 20266 min

Episode 420 -- DOJ Announces New West Coast Health Care Fraud Strike Force

The Department of Justice has announced a new West Coast Health Care Fraud Strike Force, signaling an expansion of federal enforcement efforts targeting health care fraud, telemedicine schemes, kickback arrangements, and technology-enabled billing misconduct. In this episode, Michael Volkov examines DOJ’s evolving enforcement strategy, including the growing use of data analytics and AI-driven investigations, increased scrutiny of private equity-backed health care entities, and heightened expectations for compliance oversight. Michael also discusses practical compliance lessons involving billing audits, telehealth controls, third-party risk management, and board-level governance in an increasingly aggressive enforcement environment

May 29, 20266 min

Episode 419: Polymarket Insider Trading Charges Illustrate DOJ and CFTC Prediction Markets Enforcement Strategy

Recent insider trading charges connected to Polymarket highlight the Department of Justice and Commodity Futures Trading Commission’s evolving enforcement strategy toward prediction markets and digital trading platforms. In this episode, Michael Volkov analyzes how regulators are applying traditional insider trading, fraud, and market manipulation theories to emerging event-based trading ecosystems. Michael also explores the growing compliance expectations for prediction market operators, including surveillance systems, AML controls, information barriers, and governance frameworks as DOJ and the CFTC increase scrutiny of digital market integrity risks.