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

Michael Volkov on LinkedIn | Twitter

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

Michael Volkov on LinkedIn | Twitter

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

Michael Volkov on LinkedIn | Twitter

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

Michael Volkov on LinkedIn | Twitter

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

Michael Volkov on LinkedIn | Twitter

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

Is AI a magic bullet - or just another tool in the compliance toolkit?

What really happens when you let algorithms near your risk decisions?



In this episode of Corruption, Crime and Compliance, Christian Focacci, founder and CEO of Threat.Digital, returns for a thoughtful and highly practical conversation about the state of artificial intelligence in compliance and third-party risk management. Christian’s platform is at the forefront of using large language models and real-time data to transform how companies identify and manage risk - without losing sight of the human judgment that still needs to guide every decision. He and Michael explore what's changed in the AI landscape over the past year, what’s misunderstood about the technology, and how compliance teams can strike the right balance between innovation and accountability.

You’ll hear them discuss:

• Why Christian believes you shouldn’t use AI unless it’s truly the right tool for the job, and how this philosophy shapes how Threat.Digital builds and deploys its systems
• What large language models actually are, how they function under the hood, and why most people fundamentally misunderstand how they learn and process information
• The growing demand for corporate AI governance, how some risk committees are creating unnecessary delays, and why many internal processes are still focused on the wrong questions
• How Threat.Digital uses AI to reduce noise in due diligence, replacing bloated, unfiltered search results with clear, high-quality summaries supported by verifiable sources
• Why the real power of AI isn’t about replacing humans, but about expanding what can be reviewed - moving from 10 data points to 10,000, while helping compliance professionals focus only on what matters
• The future of due diligence: chaining AI tasks to build multi-layered investigations that trace ownership, pull third-party records, and surface hidden risks in real time
• How AI is revolutionizing name screening and sanctions checks by eliminating irrelevant fuzzy matches, freeing teams from chasing meaningless alerts and allowing them to act on true risks with confidence

Resources

Christian Focacci on the Threat.Digital | LinkedIn | Email: [email protected]

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

What if your trade compliance misstep became tomorrow’s federal prosecution headline? In this episode, Michael Volkov issues a powerful warning to corporate leaders and compliance professionals: the DOJ is no longer treating trade violations as minor infractions—they're targeting them as fraud under the False Claims Act. With trade compliance now framed as a national security issue, this administration is on a mission to protect domestic industries and punish companies that cut corners. If your organization engages in international trade—especially with China—this episode is a must-listen.

You’ll hear him discuss:

• Why corporate leaders should not confuse the pause in FCPA enforcement with a wider drop in corporate prosecutions, as the DOJ is intensifying its focus on other high-risk areas like customs and trade compliance
• How the False Claims Act is being used to prosecute companies for tariff evasion, misclassification of goods, and country-of-origin fraud, creating major new exposure for import-heavy businesses
• The administration’s positioning of trade compliance as a national security priority, which signals tougher penalties and more aggressive enforcement tactics
• Examples of recent DOJ cases, including multimillion-dollar settlements with Barco Uniforms, International Vitamins Corporation, and Danco Laboratories, that highlight how quickly companies can become targets
• The expanding role of whistleblowers under new DOJ incentives, making it more likely that internal missteps will be reported and investigated
• Why supply chains involving China and other flagged jurisdictions are under heightened scrutiny, and how companies can prepare for increased oversight
• The risks of becoming a public example of trade fraud, and the steps companies should take now to stay ahead of enforcement and protect their brand and bottom line

Resources

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

Is your company ready to bet its future on whether it can outpace a whistleblower to the DOJ’s door? In this episode, Michael Volkov takes a deep dive into the Department of Justice’s newly announced strategy to reshape corporate enforcement. With promises of greater clarity, reduced penalties, and fewer monitors, the DOJ wants companies to see voluntary disclosure as a smart and safe move - not a leap of faith. But behind the incentives lies a sharper edge: whistleblowers, shortened timelines, and a more assertive DOJ ready to move fast. Whether you’re in-house counsel, a compliance officer, or just trying to stay ahead of enforcement trends, this is a must-listen breakdown of what’s changed, why it matters, and what companies need to do now to avoid being caught off guard.

You’ll hear him discuss:

• How companies that voluntarily disclose, cooperate, and remediate can now qualify for a declination, even with aggravating circumstances
• Why the DOJ is promising greater transparency and fairness in enforcement to reduce fear and uncertainty around self-reporting
• What changes have been made to limit when corporate monitors are imposed, and how DOJ will control their cost and scope
• How the whistleblower program has been significantly expanded to include sanctions, tariffs, trade violations, and federal program fraud
• What benefits may still be available for companies that report after DOJ has begun an investigation, including reduced fines and no monitorship
• Why DOJ is pushing prosecutors to shorten the length of corporate investigations and avoid drawn-out resolutions
• What’s at stake if a whistleblower reports first, and how companies could lose access to key benefits by waiting too long

Resources

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

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