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 - the first FCPA declination under the Trump Administration and the first indictment. Both shed light on how DOJ is applying its policies in practice, what companies should expect, and why individuals are squarely in the crosshairs. Taken together, these cases remind listeners that while priorities may shift, the fundamentals of disclosure, cooperation, and accountability remain very much alive.

You’ll hear him discuss:

• Why Liberty Mutual’s $4.7 million disgorgement shows DOJ is sticking closely to its Corporate Enforcement Policy
• How voluntary disclosure and cooperation continue to all but guarantee a declination
• The details behind Liberty Mutual’s misconduct in India and the factors DOJ weighed in its decision
• What the Pemex indictment tells us about DOJ’s push to hold individuals accountable
• The role of disgorgement in DOJ resolutions and whether the policy might be applied with more flexibility going forward
• How luxury goods and personal perks were used in the Pemex scheme and why DOJ zeroed in on those details
• What these developments signal for companies trying to strengthen compliance programs in a shifting enforcement landscape

Resources

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The Volkov Law Group

AI promises efficiency, innovation, and new opportunities - but are companies moving too fast in the rush to adopt it? The risks are very real, from false content to flawed decision-making, and the global regulatory patchwork is only getting more complex. The challenge now is building governance and compliance frameworks that keep pace without stifling progress.



In this episode of Corruption, Crime, and Compliance, Michael Volkov explains why an AI compliance program is essential to corporate governance today.

You’ll hear him discuss:

• Why companies need to start with a clear use case and weigh benefits against potential legal and compliance risks before rolling out AI
• The evolving patchwork of regulations, including the FTC, state-level laws in the US, and the EU’s AI Act
• How sector-specific rules in healthcare, financial services, and defense add new layers of complexity
• The two biggest risks: AI-generated false content that can cause liability and reputational harm, and decision-making systems that create unfair or discriminatory results
• What strong AI governance looks like, from board oversight and compliance officers to clear policies and cross-functional committees
• The role of training, documentation, and incident reporting in ensuring responsible, transparent AI use
• Why embedding responsible AI into company values and employee performance reviews helps build a culture of accountability

Resources

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The Volkov Law Group

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 criminal enforcement action against Cadence Design Systems - a case that marks yet another major step in the DOJ’s rapidly unfolding trade enforcement strategy. We’re no longer in the FCPA era. This is a whole new ballgame, where national security and trade compliance have collided, and companies that haven’t adjusted are already behind.

You’ll hear him discuss:

• Why Cadence’s plea deal - not a DPA or NPA - is such a big deal
• How the DOJ and BIS coordinated to secure over $140 million in criminal and civil penalties
• The simple, sloppy scheme that involved fake names, hidden aliases, and blatant attempts to skirt export controls
• Why partial cooperation didn’t earn Cadence a full credit reduction - and what they failed to do
• The shocking compliance gap: only one export control officer handling global risk
• What this case signals about the DOJ’s growing focus on national security and semiconductor enforcement
• Why ethics, due diligence, and transaction monitoring are still your best defense
• How companies can avoid getting blindsided by embracing the new trade enforcement landscape

Resources

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The Volkov Law Group

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 Benchmark Report offers a goldmine of insight into how companies are (and aren’t) managing employee concerns. In this episode, Michael Volkov breaks down the key findings, regional trends, and what they really mean for compliance officers trying to build a stronger speak-up culture. NAVEX dominates the hotline market, and its annual benchmark report gives compliance professionals an unparalleled look at reporting behaviors across the globe. From rising retaliation concerns to surprising substantiation rates, the numbers speak volumes.

You’ll hear him discuss:

• Why Europe’s sharp spike in reporting rates is likely tied to the EU Whistleblower Directive
• How North American companies resolve reports faster and what that says about handling HR-driven complaints
• Why anonymous reporting is much higher in APAC, Europe, and South America and what it might reveal about employee trust
• How retaliation claims are being substantiated at drastically different rates depending on geography and legal frameworks
• What’s behind the higher substantiation rates at privately owned companies compared to public ones
• How reporting channel preferences are shifting and why phone-based hotlines may be on the way out
• What “time to report” stats reveal about fear, hesitation, and the need for cultural change in the workplace

Resources

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The Volkov Law Group

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 enforcement landscape by linking trade compliance and the False Claims Act (FCA) in unprecedented ways. With “trade and customs fraud, including tariff evasion” now a DOJ national priority, companies engaged in international trade face growing legal and reputational risks. A recent Ninth Circuit ruling has only intensified the stakes.

You’ll hear him discuss:

• Why DOJ is combining trade enforcement and FCA cases, and what that means for companies that import goods into the U.S.
• How “reverse false claims” work in the trade context, and why import misclassification, undervaluation, or incorrect country-of-origin declarations are now high-risk areas.
• Recent high-dollar settlements - including $45 million in one case - where companies paid the price for customs fraud violations.
• The significance of the Ninth Circuit’s decision in Island Industries v. Sigma Corp., which confirmed DOJ’s ability to pursue customs fraud claims under the FCA in federal court.
• How whistleblowers, including competitors, are using FCA claims as a strategic tool in the marketplace, leading to sealed complaints and increased litigation.
• What companies should be doing now to evaluate and reinforce their trade compliance programs, from reviewing documentation and broker relationships to training and internal reporting.
• Why ignoring tariff and duty obligations - or failing to investigate them thoroughly - could be seen as deliberate indifference, exposing companies to both civil and criminal liability.

Resources

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The Volkov Law Group

What happens when companies ignore red flags, bypass legal advice, and underestimate the reach of U.S. export laws? In this episode, Michael Volkov unpacks two major enforcement actions from the Department of Commerce’s Bureau of Industry and Security (BIS) and the Treasury Department’s Office of Foreign Assets Control (OFAC). These cases serve as cautionary tales for companies navigating complex trade and sanctions landscapes, highlighting the steep costs of compliance failures, even when violations aren't willful.

You’ll hear him discuss:

• BIS’s $4.25 million penalty against Alpha and Omega Semiconductor (AOS) for 15 violations of the Export Administration Regulations (EAR), including unauthorized shipments to Huawei
• How AOS disregarded legal advice and internal compliance warnings while continuing to export EAR99 items from the U.S. to an Entity List company
• The significance of BIS’s finding that even non-willful violations will trigger serious enforcement consequences
• OFAC’s $608,825 settlement with Key Holding LLC over Cuban sanctions violations linked to its Colombian subsidiary, Key Colombia
• How a failure to implement sanctions compliance after acquiring a foreign affiliate exposed Key Holding to U.S. jurisdiction - and liability
• The importance of post-acquisition compliance integration and automated screening in mitigating enforcement risk
• Why these cases mark a return to traditional administrative enforcement priorities and serve as stark reminders of jurisdictional reach

Resources

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The Volkov Law Group

Could your supply chain be funding cartels without you realizing it? In today’s complex global economy, companies are grappling with a dual challenge - the urgent need to unravel their supply chains and the immediate recalibration of due diligence systems to detect links to cartel and transnational criminal organizations (TCOs). With the Department of Justice sharpening its focus on both direct prosecutions and financial facilitators, global companies must prepare for heightened scrutiny. Michael breaks down the mounting risks, enforcement priorities, and practical steps companies must take to protect themselves from becoming unwitting participants in criminal operations.

You’ll hear him discuss:

• How DOJ’s new two-pronged enforcement strategy is bringing corporate facilitators of cartels and TCOs into the crosshairs
• Why traditional due diligence no longer goes far enough, especially with "Nth Party" risks buried deep in supply chains
• How cartels and TCOs exploit legitimate businesses in sectors like logistics, agriculture, mining, and construction
• The importance of identifying beneficial ownership and tracing complex corporate structures across jurisdictions
• Red flags to watch for, from nominee arrangements and shell companies to unexplained wealth and layered financial flows
• How cartels are adapting with fake websites, fake bios, and cryptocurrency to mask illicit activities
• What companies must do to modernize their compliance systems with open-source tools and workflow automation
• Why trade-based money laundering, remittance services, and decentralized platforms are growing areas of concern

Resources

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The Volkov Law Group

What happens when a company inherits a sanctions violation through acquisition, and acts fast to fix it? Can a robust post-acquisition response really save a parent company from prosecution? In this episode, Michael Volkov unpacks the fascinating DOJ-led global enforcement action against UNICAT Catalyst Technologies - a case that reflects the U.S. government's intensifying focus on trade enforcement across sanctions, export controls, and customs. This resolution marks the first declination under DOJ’s National Security Division M&A policy, showcasing the power of voluntary disclosure, cooperation, and remediation in today’s enforcement environment.

You’ll hear him discuss:

• How DOJ, OFAC, BIS, and CBP coordinated parallel resolutions against UNICAT
• The $3.3 million forfeiture and additional penalties tied to underpaid duties and unlawful exports
• Why DOJ declined prosecution of UNICAT’s parent company, White Deer, under its M&A policy
• The former CEO’s role in orchestrating 23 unlawful sales to Iran, Venezuela, and Cuba
• The importance of identifying willful intent in sanctions violations — and when DOJ disclosure is required
• The risks of failed pre-acquisition due diligence and the value of strong post-acquisition integration
• How concealment tactics like falsified invoices and coded emails were used to hide dealings with sanctioned entities
• Key lessons for global companies navigating the new era of trade compliance and enforcement

Resources

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The Volkov Law Group

Are your trade compliance programs truly airtight - or are they just good enough to get caught? In this episode, Michael breaks down why tariff and trade violations are now squarely on DOJ’s radar, and why the heat is rising fast for importers, especially those dealing with Chinese goods. With enforcement priorities shifting, companies are at increased risk of both regulatory investigations and full-blown criminal prosecutions. This episode is a wake-up call for compliance professionals and legal teams - if you think tariff enforcement is still a civil issue, think again.

You’ll hear him discuss:

• Why Customs and Border Patrol and Homeland Security Investigations are stepping up referrals and actions
• How companies try to gain a competitive advantage by evading tariffs - and why it’s an “inevitable result” regulators are watching closely
• The most common tariff evasion schemes, including misclassification under HTS codes, transshipment, undervaluation, and false certification of origin
• Why importing from China under Section 301 is now considered a high-risk activity
• The specific risks surrounding steel and aluminum imports under Section 232 tariffs
• Examples of recent DOJ cases, including plywood, flooring, and mosaic tile fraud, and what they signal for future enforcement
• How AI and data analytics are being used by investigators to spot anomalies and build cases
• The difference between Section 301 and 232 tariffs - and how they reflect different policy objectives
• How rising tariffs and fewer exclusions under the Trump administration are reshaping the trade compliance landscape
• The statutes DOJ is using for criminal charges, including 18 U.S.C. §§ 371, 545, and 1341

Resources

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The Volkov Law Group

Has the pendulum swung back on FCPA enforcement - and will companies be ready when it hits? Is the DOJ’s renewed push on FCPA enforcement a strategic shift - or just old wine in a new bottle?

In this episode, Michael discusses the return of the Justice Department to the FCPA enforcement arena. In a significant development, DOJ announced the resumption of FCPA enforcement, accompanied by a new set of enforcement guidance principles. This guidance is more than policy - it’s a statement of priorities and strategy that will shape how FCPA investigations and prosecutions unfold. While the number of attorneys in DOJ’s FCPA Unit has declined, U.S. Attorneys' Offices across 94 districts now have increased authority to investigate and prosecute FCPA cases with less oversight. The result? Potentially broader, faster, and more decentralized enforcement. As always, the devil is in the details - and the June 9 DOJ FCPA Guidance Memo delivers plenty.

You'll hear him discuss:

• DOJ’s renewed emphasis on prosecuting individuals over corporations, especially when misconduct can’t be directly linked to senior leadership
• How companies may now have stronger arguments to avoid liability if the wrongdoing is isolated to a small group
• Expanded autonomy for U.S. Attorneys’ Offices and what this means for enforcement volume and consistency
• The DOJ’s prioritization of cases that directly impact U.S. national interests and corporate competitiveness
• Increased scrutiny of links to cartels and transnational criminal organizations, including risks hidden in supply chains and third-party relationships
• The push for faster, more efficient investigations to avoid the years-long white-collar case backlog
• Guidance on when facilitating payments, gifts, or travel fall under FCPA exceptions - and why these rarely matter in major prosecutions
• Why cooperation, early disclosure, and individual accountability may now be companies’ best bet for avoiding charges altogether
• The DOJ’s sharpened focus on national security sectors like defense, critical infrastructure, and technology

Resources

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group