Podcast
Corruption Crime & Compliance
Hosted by Michael Volkov · EN
Michael Volkov tackles the current and hot topics in the legal realms of corruption, crime, and compliance.
41episodes
Episodes
Newest firstAll episodes
Has DOJ Enforcement Shifted Rather Than Slowed Down?
2d ago00:01:28Tap to summarizeEveryone’s talking about the DOJ going soft on crime.I want to push back on that narrative because I think it’s incomplete and, honestly, a little dangerous if compliance officers believe it.Yes, traditional FCPA and bribery prosecutions have slowed, but look at where the resources actually went. Trade enforcement is exploding. Sanctions enforcement is aggressive and getting more aggressive by the month.And here’s the one that should really get your attention: the False Claims Act is now being used aggressively against companies for tariff circumvention and customs fraud, with qui tam relators lining up to bring those cases.This isn’t a retreat. It’s a reallocation.DOJ has simply moved its firepower to where the current priorities sit: trade, tariffs, sanctions, export controls, and national security.If your compliance program is still built entirely around FCPA risk and you haven’t retooled for trade and sanctions exposure, you are exposed right now, today.Update your risk assessment. This is not the moment to stand down.The Ethics and Compliance Q and A show is produced by One Stone Creative.
Transcribe →Episode 439 -- The Scoular Company FCPA Resolution
2d ago00:11:11Tap to summarizeIn this episode of Corruption, Crime and Compliance, Michael Volkov breaks down the Justice Department's $10.2 million foreign bribery resolution with The Scoular Company, an Omaha-based agricultural supply chain company that used customs brokers to pay more than $400,000 in bribes to Mexican officials over six years so that contaminated grain shipments could cross the U.S.-Mexico border despite failed inspections. Volkov walks through the mechanics of the scheme, a strikingly simple pattern of $2,000 per-train payments disguised on invoices as "reinspection fees," and explains why DOJ treated the case as an aggravated national security matter after determining that some of the bribe money ultimately reached individuals tied to a border cartel, even though Scoular itself had no knowledge of that connection. The episode also unpacks how DOJ applied its Corporate Enforcement and Voluntary Self-Disclosure Policy to the resolution, distinguishing between the voluntary disclosure credit Scoular did not earn and the cooperation and remediation credit it did, resulting in a three-year deferred prosecution agreement, a 25 percent reduction off the bottom of the sentencing guidelines, and no independent monitor. Volkov closes with practical takeaways for compliance officers on managing customs brokers as high-risk third parties, testing the substance behind recurring payments, and moving quickly on voluntary disclosure decisions once potential misconduct surfaces internally.
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Should Compliance Programs Relax When DOJ Enforcement Slows Down?
4d ago00:01:40Tap to summarizeWhen it comes to DOJ enforcement, the pendulum swings, and it always returns. Don’t let it knock you off your feet.I’ve been watching the headlines, and so have you. Fewer corporate guilty pleas, non-prosecution agreements for Alibaba and Eagle Bank, charges dropped against Boeing and Halkbank from Turkey.The word from Main Justice is: hold individuals accountable, go easier on companies. I get why some executives are breathing a sigh of relief.But here’s my message to every compliance officer out there: do not read this as permission to relax.Enforcement priorities are cyclical. Administrations change. Statutes of limitations run long. The conduct you tolerate today under a lenient DOJ can absolutely come back across your desk in the future, with a lookback period that reaches right back to right now.And let’s not forget: non-prosecution agreements still require admissions, still require massive fines, and still require you to fix your program. They’re not a free pass. That’s a warning shot.Stay vigilant. Keep building your program like the next administration is already watching, because eventually it will be.The Ethics and Compliance Q and A show is produced by One Stone Creative.
Transcribe →Episode 438 -- The Fight to Save the Corporate Transparency Act: An Urgent Update
5d ago00:19:57Tap to summarizeIn this update episode of Corruption, Crime and Compliance, Michael Volkov speaks with Erica Hanichak of the FACT Coalition and Frank Russo of Modern Fortis about the current fight over the Corporate Transparency Act, the 2021 law requiring companies to report their beneficial owners to a secure Treasury Department database in order to close off the U.S.'s longstanding status as an easy jurisdiction for setting up anonymous shell companies used in money laundering, human trafficking, and fraud. Hanichak and Russo describe how the law's implementation has faced litigation and a legislative repeal push that narrowly cleared the House Financial Services Committee despite broad, bipartisan, cross-sector opposition from law enforcement groups, financial institutions, and anti-trafficking organizations, all of whom view beneficial ownership data as a foundational tool for tracing who truly finances and benefits from organized criminal networks. The conversation also flags the administration's forthcoming final rule, which reportedly would exempt more than 99.98% of the entities Congress originally intended to cover, and closes with a direct call for the compliance community to engage with lawmakers to preserve and strengthen, rather than gut, the beneficial ownership reporting framework that due diligence programs increasingly depend on.
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Is Your Compliance Program Losing Its Seat at the Table?
1w ago00:01:33Tap to summarizeIs your compliance program being demoted?Let’s talk about something that should worry every compliance officer. The stature of the profession is slipping.For years, the trend line was clear. Compliance officers moved out from under the general counsel, got direct lines of reporting to the CEO, and direct lines to the board.That mattered. It wasn’t just symbolic. It meant compliance had real influence before decisions got made, not after.Now look at the data. The latest Compliance Week survey found reporting lines are sliding back toward legal. Fewer CCOs sitting with the board, fewer with a direct line to the CEO, and compliance officers are telling us off the record that they feel pushed to the side.Here’s my worry. When you add a layer between compliance and leadership, you’re sending a message to your employees, to your regulators, to the market about how much this function actually matters to you.Don’t let that message be sent on your watch. Fight for your seat. Your organization needs it more than ever.The Ethics and Compliance Q and A show is produced by One Stone Creative.
Transcribe →Episode 437 -- Where Your CCO Reports Tells Me Everything: The Quiet Backslide in Compliance Reporting
1w ago00:08:35Tap to summarizeMichael Volkov examines a troubling backslide in corporate governance: the quiet movement of chief compliance officers back under the general counsel after years of progress toward direct CEO reporting lines. Michael explains why the CCO's reporting structure is the single clearest signal a company sends about the value it places on compliance — shaping whether compliance influences business strategy at the design stage or is reduced to an after-the-fact cleanup function. He makes the case for a direct CCO reporting line to the CEO paired with a formal dotted line to the audit committee, including guaranteed executive sessions and unrestricted escalation authority, and warns that subordinating compliance to legal fosters a "mere compliance" mindset — meeting minimum legal requirements rather than building an ethical culture that drives employee retention, customer trust, and long-term business success. Michael closes with concrete action items for boards and compliance leaders, reminding listeners that regulators scrutinize CCO empowerment and that demoting compliance to save a line item is like canceling insurance to improve quarterly cash flow.
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Is a Quiet Compliance Hotline Really Good News?
2w ago00:01:37Tap to summarizeIn the compliance world, no news is not good news.Let me ask you a question every CCO should be asking right now: Are your employees actually reporting and using your hotline to report legitimate concerns?Too many compliance officers look at a quiet hotline and breathe a sigh of relief. No calls, no complaints. Must mean everything’s fine.I’m here to tell you that’s backward. A silent speak-up line isn’t good news. It’s a red flag.Here’s why: misconduct doesn’t disappear just because nobody’s reporting it. What disappears is trust. Trust that raising an issue will be taken seriously. Trust that there’s no retaliation waiting on the other side.When that trust is gone, people don’t stop seeing problems. They just stop telling you about them, and that’s exactly when whistleblower risk goes up, not down, because the next person who sees something is going straight to the regulator instead of you.So benchmark your reporting volume against your industry. Look at your trends over time. If your numbers are flat or falling while everyone around you is seeing increases, don’t celebrate. Investigate.The Ethics and Compliance Q and A show is produced by One Stone Creative.
Transcribe →Episode 436 -- Internal Investigations and AI
2w ago00:11:05Tap to summarizeMichael Volkov examines how artificial intelligence is transforming internal investigations — and what the Justice Department now expects from companies navigating this new landscape. Michael breaks down DOJ's updated Evaluation of Corporate Compliance Programs, which directs prosecutors to scrutinize how companies assess AI risks, whether compliance functions have adequate access to data and analytics resources, and what controls prevent the reckless misuse of new technologies. He then walks through the five most dangerous failure modes when AI meets internal investigations — hallucinated witness summaries, missed hot documents, privilege waiver through third-party AI tools, discoverable prompt trails, and investigator overreliance — before turning to the emerging frontier: investigations where AI itself is the subject, including employee AI misuse, deepfake and synthetic evidence, and the growing class of AI whistleblowers protected under SOX and Dodd-Frank. Michael closes with six concrete action items for building an AI-ready investigation protocol that will withstand regulatory scrutiny.
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What Is the Ethics Premium?
2w ago00:01:44Tap to summarizeThe root of every strong compliance program is a strong culture.I say this on every episode, and I’m going to keep saying it. Culture is the single most important control that your compliance program builds. It’s at the heart of every compliance program—not the policy binder, not the training module. Culture.Here’s what the research really shows: companies with strong ethical cultures perform better financially. They’re more sustainable because employees believe in the mission. They don’t cut corners when nobody’s watching. And employee engagement and satisfaction go up—way up—when people trust that their company will do the right thing, even under pressure.Think about what this means practically: lower turnover, higher productivity, fewer whistleblower complaints turning into full-blown investigations because people raise issues early instead of burying them.That’s the ethics premium, and it’s real.So, if you’re a CCO fighting for budget, stop pitching compliance as a cost center. Pitch it as what it really is: the thing that makes your business more successful, more sustainable, and a place people actually want to work.Culture isn’t a soft metric. It’s your bottom line.The Ethics and Compliance Q and A show is produced by One Stone Creative.
Transcribe →Episode 435 -- Inside the Mind of the CCO: Aaron Nicodemus on Compliance Trends, AI Governance, and Reporting Lines
2w ago00:35:57Tap to summarizeIn this episode of Corruption, Crime and Compliance, Michael Volkov talks with Aaron Nicodemus, editor-in-chief of Compliance Week, about the state of the compliance profession and the findings of Compliance Week's latest "Inside the Mind of the CCO" survey. They discuss a troubling reversal in reporting lines, with more compliance officers now reporting through general counsel rather than directly to CEOs or boards after several years of progress toward greater independence, and what that structural shift signals about how seriously organizations value the function amid shifting political winds and uneven federal enforcement priorities. The conversation turns to artificial intelligence as both the defining opportunity and risk of the moment: survey data shows AI use across organizations has jumped to roughly 85%, yet a significant share of compliance officers report no governance plan is in place, leaving gaps around data privacy, algorithmic decision-making, hallucinated outputs, and "shadow AI" used by employees and third-party vendors alike. Nicodemus and Volkov agree that compliance is uniquely positioned to build the guardrails that let organizations use AI productively rather than recklessly, and they close by identifying data privacy, third-party risk management, and responsible AI adoption as the three pillars compliance officers should be watching most closely in the years ahead.
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