Episode 405 — DOJ Balt Declination: Individual Accountability in Action
The U.S. Department of Justice declined to prosecute Balt Medical despite a multi‑year foreign‑bribery scheme, citing the company’s prompt self‑disclosure, full cooperation, and effective remediation. Simultaneously, DOJ charged two individuals alleged to have orchestrated the payments to a state‑owned hospital physician. The case illustrates how DOJ’s Corporate Enforcement Policy rewards corporate transparency while holding responsible persons personally accountable. Companies must now provide prosecutors with clear evidence linking misconduct to specific actors to secure favorable outcomes.
BIS Imposes $1.6 Million Civil Penalty in Enforcement Action Involving Unlicensed Exports to Entity List Parties
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) imposed a $1.6 million civil penalty on Solventum Corporation for exporting EAR99 liquid‑cel membrane contactors to Entity List firms without the required licenses. The violations involved shipments to Semiconductor Manufacturing...
Episode 404 — Venezuela Sanctions Update
The U.S. Treasury’s Office of Foreign Assets Control (OFAC) has issued a suite of new general licenses that partially reopen Venezuela’s oil, gas, and mineral sectors to American and allied companies. The framework is not a full sanctions lift; it...
Proactive Compliance Requires More Than Automation — It Demands AI-Driven Strategy
Compliance is moving from a reactive, post‑incident model to an AI‑driven, forward‑looking strategy. The Optro report shows that high‑maturity firms are six times more likely to embed AI across GRC functions, with 72% using it for proactive risk tracking and...
Episode 402: Paul Allen: The Promise of AI, Governance and Public Trust
In the latest episode of *Corruption, Crime and Compliance*, entrepreneur Paul Allen—founder of Ancestry.com and Soar.com—introduces CitizenPortal.ai, an AI‑driven civic intelligence platform designed to make government activity more transparent and accountable. Allen argues that artificial intelligence should augment, not replace,...
OFAC’s TradeStation Enforcement Action: A Case Study in “Set It and Forget It” Compliance Failures
The U.S. Treasury’s Office of Foreign Assets Control (OFAC) fined TradeStation Securities about $1.1 million after the broker processed 481 trades totaling roughly $4.4 million for users in Iran, Syria and Crimea. Although TradeStation had a layered sanctions‑compliance framework, a 2018 mobile‑app...
The Continuing Threat of Individual FCPA Enforcement Actions in 2026
The final quarter of 2025 saw a modest resurgence in FCPA activity after the June 2025 DOJ guidelines, but the key trend is that individual enforcement remains robust. While the revised Corporate Enforcement Policy encourages corporate leniency through self‑disclosure and...
Episode 400 — Reopening 9/11 — A UK Supreme Court Battle Over Truth, Power, and Accountability
Matthew Campbell’s quest to reopen the inquest into his brother’s death at the World Trade Center has reached the UK Supreme Court. The Attorney General denied a fresh inquest, and lower courts upheld that refusal, raising the question of whether...
Webinar: AI Risks, Ethics & Compliance Programs — Building a Defensible Governance Framework
The Volkov Law webinar on April 7, 2026 will guide legal and compliance leaders through building a defensible AI governance framework. It distinguishes AI risk from traditional technology risk, highlighting high‑stakes decision‑making systems versus productivity tools. The session outlines board‑level...
BIS Fines Navy Contractor for Illegally Sharing Controlled Military Specifications With Chinese Manufacturer
The U.S. Department of Commerce’s Bureau of Industry and Security imposed a $374,474 civil penalty on California‑based satellite supplier Vizocom for illegally exporting controlled technical data on UHF military antennas to a Chinese manufacturer. Vizocom uploaded detailed specifications to a...
Third-Party Risk Management Must Now Confront AI, Cybersecurity, and Technology Risk Head-On
Third‑party risk management is undergoing a fundamental shift, requiring AI, cybersecurity and broader technology risk to be embedded in core vendor assessments. Traditional categories like corruption and sanctions remain relevant but are insufficient as vendors now provide cloud services, AI...
Episode 399 — Vera Cherepanova on Boards of the Future
Vera Cherepanova, a Chartered Accountant and award‑winning ethics specialist, appears on Episode 399 to discuss her work with Boards of the Future, a nonprofit that advises corporate boards on ethics, risk and compliance. She highlights the growing need for directors with strong...
Episode 398 — Anik Shah, Sandisk Head of Compliance: Anti-Corruption Developments and Managing Risks
Episode 398 features Anik A. Shah, Sandisk’s Director of Anti‑Bribery and Anti‑Corruption, discussing the latest anti‑corruption developments and risk‑management strategies. Shah draws on more than 15 years of experience, including a tenure at the SEC where he led multi‑jurisdictional investigations...
U.S. Issues New OFAC and BIS Guidance on Cuba: What Exporters Need to Know
The U.S. Treasury’s OFAC announced a favorable licensing policy for resales of Venezuelan oil destined for Cuba, while the Commerce Department’s BIS clarified that the EAR’s License Exception SCP can cover petroleum shipments to eligible Cuban private‑sector and humanitarian end‑users....
Cybersecurity’s New Frontline: What the 2026 CrowdStrike Global Threat Report Reveals
The 2026 CrowdStrike Global Threat Report shows attackers leveraging generative AI to accelerate breach timelines, with average breakout time now just 29 minutes—a 65% increase in speed. AI‑enhanced reconnaissance, phishing, and automated evasion are compressing response windows, while identity compromise...
