What happens when the world’s most influential anti-bribery law is abruptly paused? Is transparency merely a compliance box-tick—or the most powerful tool we have against global threats like kleptocracy, sanctions evasion, and illicit finance? In this eye-opening episode of Corruption, Crime, and Compliance, Michael Volkov is joined by two powerhouse experts in the global fight against corruption: Scott Greytak and Josh Birenbaum (*see ‘’About Guests below). Together, they break down the sweeping implications of the U.S. government’s pause on Foreign Corrupt Practices Act (FCPA)enforcement, the gutting of the Corporate Transparency Act (CTA), and what all of this means for business leaders, policymakers, and the international community.

When the United States hit pause on FCPA enforcement, the global anti-corruption landscape shifted. Scott and Josh explore how companies are reacting, how allies are stepping up enforcement, and why transparency is emerging as a national security imperative. They offer a forward-looking conversation filled with insights for compliance professionals, risk officers, and anyone committed to ethical business in a volatile world.

You’ll hear them discuss:

• Why the U.S. government's pause on FCPA enforcement shocked the global anti-corruption community—and why companies should still stay the course with compliance regardless of political signals.
• How the Corporate Transparency Act, once seen as the most significant U.S. anti-money laundering law in a generation, has been quietly gutted—leaving a dangerous gap in the fight against shell companies and financial crime.
• What it means that U.S. companies are now incentivized to form anonymously domestically to avoid ownership disclosure—inviting kleptocrats, traffickers, and foreign adversaries to hide in plain sight.
• Why global businesses must prepare for a sharp rise in trade compliance enforcement, as tariffs, export controls, and sanctions take center stage in economic security—and why transparency is essential to managing these risks.
• How foreign enforcers, especially in Europe, are beginning to step up—but why no alliance or coalition can truly fill the vacuum left by a retreating United States.
• What makes transparency not just a compliance tool, but a weapon against geopolitical threats—from Xinjiang’s forced labor camps to Russian shadow fleets and fentanyl trafficking.
• How transparency can be hardwired into foreign aid policy to protect U.S. taxpayer money, prevent narco-state development, and give American businesses a fair shot abroad.
• Why there’s still hope—from new bipartisan support for anti-corruption measures to the emergence of a national security lens on transparency across Congress, federal agencies, and the private sector.

About Guests

Scott Greytak is an anticorruption attorney and the Director of Advocacy for TI US. His work focuses on designing anticorruption laws and policies, organizing and leading ideologically inclusive coalitions, and lobbying the U.S. Congress and administration. Greytak was named a Top Lobbyist in 2021, 2023, and 2024 by the National Institute for Lobbying & Ethics.

Josh Birenbaum is the deputy director of FDD’s Center on Economic and Financial Power, focusing on illicit finance risks and global corruption. Previously, Josh was the research and policy analyst at TRACE International, producing articles, book chapters, op-eds, model policies, industry reports, and speeches on sanctions, export controls, corruption, conflict minerals, money laundering, human rights, illicit finance, and other topics.

Resources

Scott Greytak on LinkedIn | Email - [email protected]

Josh Birenbaum on LinkedIn | Email - [email protected]

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

What if your next import shipment becomes the centre of a federal enforcement action — not because of criminal intent, but because of a mistake? In today’s episode, Michael Volkov breaks down the expanding power and reach of U.S. Customs and Border Protection (CPB) and what it means for businesses navigating an increasingly aggressive trade enforcement landscape. With the Trump Administration’s re-defined objective of fair trade, companies across all sectors need to brace for scrutiny, adapt to evolving risks, and rethink their compliance strategies.

You’ll hear him discuss:

• The Trump Administration’s focus on fair trade and why CPB has become a central enforcement agency under this new agenda
• How CPB exercises its authority to impose regulatory penalties, seize goods, and refer serious cases for civil or criminal prosecution
• The legal standards that determine the severity of violations — fraud, gross negligence, or negligence — and how each carries different penalty thresholds
• Why the materiality of a false statement or omission is a key factor in determining whether a violation has occurred
• The importance of voluntary disclosure and how it can significantly reduce potential penalties and protect company reputation
• The step-by-step process of CPB administrative enforcement, including investigations, pre-penalty notices, appeals, and mitigation options
• The expanding impact of the Enforce and Protect Act (EAPA), and how companies can be held accountable for evading anti-dumping and countervailing duties
• Why businesses must now take a closer look at their import documentation, supply chain practices, and overall trade compliance posture

Resources

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

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 impactful compliance programs from those that are merely operational. Based on insights from 1,500 global ethics and compliance professionals, this year’s report draws a clear line between high-impact and medium-impact programs—and what it takes to bridge the gap. The conversation highlights urgent risks, cultural disconnects, and the strategic value of automation, data, and leadership alignment in shaping tomorrow’s compliance functions.

You’ll hear him discuss:

• How high-impact programs are defined by their strategic use of automation, data analytics, and benchmarking tools to drive measurable compliance outcomes
• Why third-party risk management—including due diligence and supply chain oversight—is a defining trait of the most effective programs today
• The growing trust gap between Gen Z employees and middle managers, and why this generational shift poses a cultural red flag
• The continued dominance of outdated internal systems, regulatory complexity, and budget pressure as top operational challenges facing compliance leaders
• How high-impact programs are integrating AI into both their codes of conduct and employee training, preparing teams for emerging tech risks
• What medium-impact programs can do to evolve: focus on training, automation, and peer collaboration to elevate impact and resilience

Resources

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

When The United States has hit pause on Foreign Corrupt Practices Act (FCPA) enforcement—it left many asking whether Europe will now be stepping up to lead the global anti-corruption charge. In this episode of Corruption, Crime and Compliance, Michael Volkov explores how European prosecutors are responding to the enforcement gap, why multinational companies can’t afford to slow down their compliance efforts, and how both state-level and international initiatives are reshaping the future of anti-bribery law.

You’ll hear him talk about:

• The launch of a new International Anti-Corruption Prosecutorial Task Force formed by the UK, France, and Switzerland, designed to intensify cross-border enforcement and cooperation in bribery and corruption cases.
• The task force’s formation as a direct response to the U.S. enforcement pause, signaling that European agencies are prepared to take a more prominent role in prosecuting international corruption, especially involving multinational corporations.
• California’s bold move to pursue foreign bribery under its Unfair Competition Law (UCL), reinforcing that FCPA violations remain prosecutable at the state level despite federal hesitation.
• A continued commitment by global companies to maintain strong compliance programs, reflecting awareness that international and local enforcement can still pose serious legal and financial risks.
• The unexpected dismissal of the long-running FCPA case against Cognizant executives, contrasted with the DOJ's decision to move forward with prosecutions in other high-profile cases, suggesting a selective enforcement pattern under current policy shifts.
• A landmark case by the UK Serious Fraud Office (SFO), charging a company with failure to prevent bribery—a first for the SFO to bring such a case before a jury, potentially setting a new standard for corporate liability in the UK.

Resources

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

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 episode of Corruption, Crime and Compliance, Michael Volkov breaks down the Justice Department’s sweeping new Data Security Program, enacted under Executive Order 14117 and finalized in January 2025.

You’ll hear him discuss:

• The origins of the DSP, created through Executive Order 14117 under the Trump Administration, and the key national security concerns it addresses.
• What constitutes a “covered data transaction” and the thresholds for U.S. personal and government data that trigger compliance obligations.
• The list of “countries of concern” and what it means for companies doing business with entities tied to these regions.
• The types of U.S. data covered by the DSP, including biometric, genomic, financial, and geolocation data, and the specific quantity thresholds that trigger restrictions.
• Why data brokerage and bulk human genomic data transactions are prohibited outright, raising new compliance challenges for affected industries.
• How “restricted transactions” like cloud computing services and vendor agreements are subject to conditional exceptions under the DSP.
• The critical actions U.S. companies must take during the 90-day enforcement hiatus, including vendor assessments, renegotiations, and compliance system updates before the July 8th deadline.

Resources

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

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 implications for global companies. He discusses four significant cases that underscore the necessity of robust compliance programs, particularly in light of increased DOJ enforcement actions. Through these examples, he breaks down the consequences of third-party liability, supply chain risks, and the dangers of inadequate compliance measures, offering valuable insights into how companies can proactively avoid similar pitfalls.

Cases discussed:

• British American Tobacco (BAT): The company faced a staggering $629 million settlement for circumventing North Korean trade sanctions. This case illustrates how corporate prosecutions are evolving to resemble Foreign Corrupt Practices Act (FCPA) cases, emphasizing the growing scrutiny on multinational corporations.
• Epsilon Electronics: This case clarifies the liabilities companies face when third-party distributors divert products to prohibited countries, such as Iran. Even if the company had no direct involvement in the diversion, it still bears responsibility, underscoring the importance of diligent monitoring of distribution channels.
• ELF Cosmetics: The company received a $1 million fine for importing goods containing materials sourced from North Korea. This case underscores the critical importance of conducting thorough supply chain due diligence to ensure compliance with international sanctions.
• Murad LLC: This case focuses on post-acquisition compliance failures, demonstrating the urgent need for thorough pre- and post-acquisition audits. These audits are essential to uncover potential sanctions violations and ensure that newly acquired companies adhere to compliance standards.

Resources:

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

Links to the four cases: British American Tobacco | Epsilon Electronics I Elf Cosmetics | Murad LLC

A Framework for OFAC Compliance Commitments (May 2019)

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 risks—from tariffs and trade controls to supply chain disruptions and third-party exposures. While the pressure to react is constant, the real key is staying anchored in your company’s values while making smart, timely adjustments.

Legal and compliance officers are used to adjustments and continuous improvement of their compliance programs. Building and maintaining an effective ethics and compliance program never ends — it is a continuous process. In a climate of rapid change, the strategies may feel familiar, but the risks themselves are taking new shape. To that end, Michael outlines five specific strategies for evolving your compliance program without losing your footing.

You'll hear him discuss:

• Why culture isn't just a buzzword—it's the first and most critical line of defense in volatile times
• How to run a quick-turn, focused risk assessment to identify new hotspots like sanctions, tariffs, and supply chain gaps
• The rising danger of indirect exposure to foreign terrorist organizations and cartels through third parties
• What companies need to know about tariff classification, scope, and enforcement to avoid legal and economic penalties
• Why sanctions and export controls enforcement is heating up—and what that means for your global operations
• How to recalibrate third-party risk management to account for trade-based threats and hidden ownership structures

Resources

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

This week we are pleased to bring you one of our most popular episodes of 2024. Please enjoy, and we will be back next week with more insights from the Corruption, Crime, and Compliance podcast.

How can companies build trust and drive growth in a region as politically and economically volatile as Latin America? In this episode, Nicolas Garcia - Vice President, Legal, Regional and Compliance Manager for LATAM and Orica - joins Michael Volkov to discuss the complexities of navigating compliance and leadership in LATAM. The conversation highlights how regional dynamics, such as the crisis in Venezuela, influence business operations and how cultural shifts are changing the role of compliance officers. Nicolas provides valuable insights on the evolving compliance landscape, emphasizing the importance of trust, leadership, and a strong compliance culture in driving business success in challenging environments.

Listen in as Nicolas and Mike discuss:

• The ongoing political and economic crisis in Venezuela has led to massive immigration into neighboring countries like Colombia, Chile, and Brazil, creating both economic challenges and opportunities in the region.
• Guyana is experiencing rapid growth due to foreign investment, particularly in the oil and gas sectors, standing in stark contrast to Venezuela’s decline.
• Nicholas emphasizes the shift from compliance officers being seen as enforcers to becoming strategic business partners. This transition helps companies not only meet regulatory requirements but also drive success.
• Establishing a trust-based relationship between compliance officers and leadership is essential. When compliance is integrated into the business strategy, it becomes a tool for enabling growth rather than a barrier.
• Trust in reporting systems is growing in Latin America, though fear of retaliation remains a concern. Anonymous reporting is on the rise, and substantiation rates are increasing as employees gain confidence in the system’s integrity.
• Ensuring that investigations follow due process is critical to maintaining credibility in compliance programs. It also helps improve trust and the success rate in legal outcomes.

Nicolas Garcia on LinkedIn

Nicolas Garcia on Email: [email protected]

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

This week, we are pleased to bring you one of our most popular episodes of 2024. Please enjoy, and we will be back next week with more insights from the Corruption, Crime, and Compliance podcast.

Carlos Villagrán is the Director of Compliance at CMPC, a 100-year-old Chilean-based holding company, one of the worldwide leading pulp, paper, packaging, personal care, and other forest products manufacturers. With more than 20,000 employees, CMPC has industrial operations in 9 countries (LatAm and the US) and commercial offices in the US, Europe, and China, selling and distributing its products to more than 45 countries around the world. Carlos joined CMPC to remediate and rebuild CMPC's culture and compliance program after a devastating scandal -- CMPC was prosecuted for its involvement in a decade-long conspiracy to fix prices in Peru and Chile for consumer paper products. Carlos discusses the challenges he faced in rebuilding CMPA's culture and commitment to compliance. His story is an inspiration to all legal and compliance professionals and provides important instructive lessons to corporate leaders and compliance professionals.

You'll hear Michael and Carlos discuss:

• The importance of rebuilding and rediscovering the values and purpose of CMPC after a major corporate crisis.
• The effects on market share quotas and sales prices when CMPC faced an investigation and found to be the leader of a cartel in Chile and Peru.
• How the crisis significantly impacted CMPC's reputation, leading to public protests and consumer backlash in Chile and Peru.
• CMPC’s compliance team addressed the company’s complex nature because of its diverse workforce, including data analytics experts, IT professionals, and engineers.
• How the compliance program at CMPC shifted from a traditional approach to a more cultural and system-thinking perspective, aligning with the company's values and operations.
• Success for the compliance program at CMPC is defined by the number of critical tables the team is seated on, indicating their value and integration within the business operations.

Resources

Carlos Villagran on the Web | LinkedIn

Email: [email protected] or [email protected]

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

This week we are pleased to bring you one of our most popular episodes of 2024. Please enjoy, and we will be back next week with more insights from the Corruption, Crime, and Compliance podcast.

Have you heard of the recent controversies around Boeing 737 MAX and its safety? Have you wondered what is being done about the concerns around it? In this episode of Corruption, Crime, and Compliance, Michael Volkov delves into the latest developments in the Boeing 737 MAX case, highlighting the recent plea agreement proposed by the Department of Justice (DOJ). The Boeing 737 MAX case took another dramatic turn. On July 24, 2024, the Department of Justice filed with the United States District Court for the Northern District of Texas a proposed plea agreement with Boeing. Under the Plea Agreement, Boeing will plead guilty to the original Information filed in 2021 with the Deferred Prosecution Agreement ("DPA"). The discussion focuses on Boeing's alleged failure to implement adequate compliance measures, leading to significant risks and violations, and the ongoing legal and ethical implications of the case. Tune in to hear a detailed analysis of the complexities and legal ramifications of Boeing’s recent plea agreement and what it means for corporate compliance and accountability.

You’ll hear him talk about:

• Certification Issues: Boeing failed to ensure its 737 MAX certifications were accurate, risking false certifications to the FAA.
• DOJ Plea Deal: Boeing agreed to plead guilty to conspiracy to defraud the U.S., facing opposition from victims' families who find the resolution insufficient. The plea agreement, which has been filed under Federal Rule Criminal Procedure 11(c)(1)(C), requires the Court to approve and accept the deal. The Court can reject the plea deal and require the parties to renegotiate the terms.
• Victims’ Rights: The proposed resolution has been controversial because of the opposition of the families of the victims, who have opposed the plea agreement and general disposition of DOJ's investigation and prior resolutions as insufficient to vindicate the public interest and their rights as victims of Boeing's malfeasance
• Compliance Failures: Boeing breached its DPA by not implementing effective compliance controls, particularly in safety and quality processes.
• Independent Monitor: Boeing will be monitored for three years and must invest $455 million in compliance and safety improvements.
• Ongoing Challenges: Boeing’s anti-fraud measures still have gaps, with broader implications for industries where safety is critical.

Resources:

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group