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Corruption Crime & Compliance: Daily Summaries Delivered
by Volkov Law
Corruption, Crime & Compliance is a podcast for legal and compliance professionals who want to keep up to date with the world of corporate governance, ethics, compliance, corruption and white collar crime. In each episode, Michael Volkov, a former federal prosecutor, brings his unique perspective and practical experience to cutting-edge trends in the governance and risk management landscape. Whether you’re looking to understand the latest FCPA developments, hear expert analysis on important ethics, compliance and governance trends, or simply join a community of engaged legal and compliance leaders, Michael Volkov will consistently present discussions and analysis of important issues in this fast-growing field.Welcome to Corruption, Crime & Compliance!
Latest Episodes
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- Today1 min
Are Your Patient Price Estimates Truly Transparent?
Posting your prices isn’t the same as telling patients the truth about them.On October 5th of this year, the FTC sent warning letters to 24 of the nation’s largest healthcare services companies, reminding them that patients are entitled to timely, accurate, and complete pricing, especially for scheduled non-emergency care.Failing to provide it can be an unfair or deceptive practice under the FTC Act.Here’s the part compliance officers need to hear.A partial price can be deceptive if an estimate leaves out physician fees or facility fees, or covers only part of the expected care.The patient may reasonably believe that they’ve been told the total cost.And the letters say plainly that the CMS price transparency rules are a floor, not a safe harbor.You can post every file CMS requires and still face FTC liability.The chairman went further, saying the agency will take noncompliant providers to court and that investigations are already opening.So review the whole patient journey, not just the posted file: the website estimator, the scheduling call, the financial counselor. Mystery shop a scheduled procedure.Then compare the quote with the final bill, flag separately billed physician charges, and watch the words “total” and “your cost.”If it isn’t the total, don’t call it that.The Ethics and Compliance Q and A show is produced by One Stone Creative.
- Yesterday8 min
Episode 467 -- Fewer Fines, More Prison: Criminal Antitrust Trends and Compliance Reminders
In this episode, Michael Volkov reviews six trends in criminal antitrust enforcement in 2026 and ten compliance reminders that follow from them. Drawing on the Antitrust Division's statistics, budget submission, and recent speeches by its criminal enforcement chief, he explains that criminal cases filed have rebounded from 9 in fiscal 2023 to 27 in 2025, that prison sentences more than doubled while corporate fines collapsed, and that the docket is centered on government procurement, agriculture, and labor markets, with antitrust charges increasingly paired with fraud. He also covers the Division's shift toward proactive investigations, the "two races" created by corporate leniency and the new whistleblower rewards program, and its record of trial and plea convictions. Michael closes with practical steps: map exposure, train the people who face competitors, use data to find problems first, treat pricing software as a compliance risk, build a fast reporting and leniency-decision path, preserve evidence properly, protect individuals, and keep the board informed.
- 2 days ago1 min
Are You Governing Both Sides of AI?
Most companies have AI in two different rooms. Innovation buys the tools. Compliance writes the policy. Nobody connects it.Here’s the core idea.There are two tracks in one program.Track one: use AI to strengthen compliance in screening, monitoring, third-party diligence, hotline triage, and investigations.Track two: govern the risk AI creates, from shadow AI and data leakage to unverified output, bias, and deliberate misuse.And you don’t have to wait for an AI-specific statute.DOJ’s compliance program guidance already asks how a company governs AI in both its business and its compliance program, and what baseline of human decision-making it uses to judge the tools.It also asks whether compliance has technology comparable to the business.OFAC’s 2019 framework covers your screening tools too.And Amazon and Payoneer paid penalties for weak matching results.AI isn’t a separate program. It flows through every element of the one you already have.The Ethics and Compliance Q and A show is produced by One Stone Creative.
- 3 days ago9 min
Episode 466 -- The Extreme Network OFAC Settlement
In this episode, Michael Volkov examines OFAC's October 27, 2026 settlement with Extreme Networks, which agreed to pay $1,529,685 for nine apparent violations involving exports to MMZA, a Russian defense manufacturer blocked under the 50 percent rule through its ownership by Almaz-Antey. The company had a policy to review every Russia-related dealing, yet OFAC says it ignored red flags that included MMZA email addresses and addresses in purchase orders, a distributor that supplied MMZA's website before switching to a different named end user, and customer portal registrations made under the wrong company name. Michael walks through the penalty calculation, the parallel Justice Department non-prosecution agreement and its "near-miss" characterization of the company's disclosure, and eight practical lessons: treat acquired customer lists as acquired risk, make the 50 percent rule operational, resolve paperwork mismatches with independent evidence, never treat a distributor's statement as a control, follow up on screening hits, connect compliance to what the business knows, watch portals and support channels, and oversee foreign affiliates closely.
- 1 weeks ago1 min
Can You Govern the AI You Can’t See?
You cannot govern AI you cannot see. That’s why the first step is not a policy. It’s an inventory.Once you’ve found every AI tool in your company, including the shadow ones, sort them into tiers.High-risk tools that make decisions about people or money, with human review of every output. Moderate risk, customer-facing tools with sampling and disclosure. Low-risk internal productivity tools on approved platforms.Then build your guardrails: a short, concrete, acceptable use policy that tells employees what they can and cannot paste in.Vendor diligence that asks who owns the model, where it’s hosted, and whether it trains on your data.Verification scaled to risk, because in the Avianca case, the court sanctioned the lawyers, not the chatbot.And an incident plan that covers AI-specific events like a data leak or a deepfake executive call.Here’s the 90-day plan.First 30 days: see it. Inventory and brief the board.Next 30: govern it. Tier and adopt policy.Final 30: use it. Pilot one compliance AI use case with validation.Govern first, deploy second.The Ethics and Compliance Q and A show is produced by One Stone Creative.
- 1 weeks ago9 min
Episode 465 -- The Retrenchment of Compliance: Penny Wise, Pound Foolish
In this episode of Corruption, Crime and Compliance, Michael Volkov examines the growing retrenchment of compliance and why companies that cut or sideline their programs are taking on more risk, not less. Using the Bank of America penalties as a case study, he shows how a compliance function can identify the problem, recommend an exit, and still be overruled or bypassed by the business, which is a failure of stature rather than a lack of staff. He explains why the lower priority given to FCPA enforcement does not signal lower risk overall, since the administration has reallocated resources toward trade and customs enforcement, sanctions, the False Claims Act, financial crime, health care, and national security cases, including cartel-related bribery, and he notes that the $1.21 billion in Treasury penalties does not include any announced Justice Department action. Volkov closes by arguing that ethics and compliance are not cost centers but foundations of reputation, intangible asset value, and financial performance, and he offers practical steps for compliance officers and boards to restore stature, authority, and funding.
- 1 weeks ago1 min
How Far Does Your Supply Chain Risk Go?
Your supply chain doesn’t end at your supplier. Neither does your liability.Three risks are converging on the same shipments.Sanctions. Evasion networks use transshipment hubs, shell companies, and last-minute routing changes, and regulators now expect you to screen your cargo, not just your counterparties.Forced labor. U.S. law presumes goods linked to restricted regions or entities were made with forced labor unless you prove otherwise.And one blacklisted component several tiers down got thousands of luxury vehicles stopped at U.S. ports in 2024.Add country-level forced labor tariffs in the U.S. and an outright EU product ban fully applicable at the end of 2027.Then there’s human trafficking, which rarely announces itself.Look for workers in debt from recruitment fees, employers holding passports, delayed wages or inflated deductions, and overtime enforced by threats.The fix is the same for all three.See below the first tier.Assess residual risk based on a supplier’s tested controls rather than its ZIP code.Write enforceable contract terms, verify with audits and worker channels, and fix root causes instead of simply dropping a supplier.Build evidence, not a policy binder, before a customs officer asks a question you can’t answer.The Ethics and Compliance Q and A show is produced by One Stone Creative.
- 1 weeks ago6 min
Episode 464 -- Responsible AI Use
Michael Volkov examines why every organization needs a responsible AI use policy now, as employees adopt AI tools faster than companies can govern them. Drawing on court sanctions against lawyers for AI-fabricated citations, SEC "AI washing" enforcement actions, and data leaks into public chatbots, Michael explains that these failures stem from weak governance rather than weak technology. He highlights DOJ's Evaluation of Corporate Compliance Programs, which now asks how companies manage emerging-technology risks, along with the EU AI Act and new U.S. state rules. Michael then outlines eight essentials of an effective policy: controlling approved tools, classifying permitted, high-risk and prohibited uses, protecting data, keeping humans accountable, verifying outputs, ensuring transparency, governing third-party AI, and building a cross-functional governance structure. He closes by urging CCOs to lead the effort, embed AI in the enterprise risk assessment, and back the policy with training, monitoring and a speak-up channel.
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About Corruption Crime & Compliance
Corruption, Crime & Compliance is a podcast for legal and compliance professionals who want to keep up to date with the world of corporate governance, ethics, compliance, corruption and white collar crime. In each episode, Michael Volkov, a former federal prosecutor, brings his unique perspective and practical experience to cutting-edge trends in the governance and risk management landscape. Whether you’re looking to understand the latest FCPA developments, hear expert analysis on important ethics, compliance and governance trends, or simply join a community of engaged legal and compliance leaders, Michael Volkov will consistently present discussions and analysis of important issues in this fast-growing field.Welcome to Corruption, Crime & Compliance!
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