Corruption Crime & Compliance

Michael Volkov
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Michael Volkov tackles the current and hot topics in the legal realms of corruption, crime, and compliance.

  1. 4D AGO

    Episode 391 -- DOJ's 2025 False Claims Act Report Cites $6.8 Billion in Recoveries

    The Justice Department has increased False Claims Act prosecutions, reflecting a continued focus on healthcare fraud and a new initiative on trade fraud. DOJ announced the largest annual recovery figure in the FCA's history -- $6.8 billion in settlements and recoveries.    FCA whistleblowers filed a record number of new cases -- 1,297 lawsuits and the government initiated 401 investigations. Since 1986, DOJ has recovered a total in excess of $85 billion.   DOJ is taking full advantage of the power provisions of the FCA that include treble damages, broad liability coverage, and favorable amendments adopted to increase government leverage.   Health care fraud remained the primary source of FCA settlements. Approximately $5.7 billion of the total $6.8 billion related to actions against healthcare companies. Notably, DOJ continued and expanded its success in three major areas: Managed Care, Prescription Drugs, and Medically Unnecessary Care.

    14 min

  2. FEB 1

    Episode 390 -- A Realstic Examination of AI Risks

    From my perspective, hopefully a reasonable one, there is a little too much AI-Risk Hype. Not to belittle the experts or ignore potential risk concerns but this is getting a little carried away.    The compliance industry appears to be taken over by AI-this and AI-that. Third party risk bleeds into major AI risks, corporate governance needs to incorporate AI risks, and policies and procedures have to incorporate AI risks, while of course no risk assessment is worth its sale unless there is a discussion of dramatic AI risks.   My first response is whoa -- let's all take a deep breath. The best self-help tactic when experiencing anxiety is to take a deep breath, a proven remedy. The AI discussion is veering off into a racing brain phenomena where the compliance profession is sprinting to keep up with the newest hypothetical risk.   So let's take a calm and deliberate review of some of the key issues.

    13 min

  3. JAN 28

    Episode 389 -- 2025 Review of Trade Enforcement

    The most significant compliance and enforcement issue remains trade enforcement -- sanctions and export controls. In the second posting, I want to focus on the new and interesting development in this area: the use of the False Claims Act to capture violations of tariffs and customs duties.   With all the hype on the trade compliance front, when you calculate the numbers relating to criminal enforcement, 2025 was a slower year than 2024. That is understandable since there is always a hiccup or delay when a new Administration takes power.    From the administrative standpoint, however, OFAC and Commerce's Bureau of industry and Security ("BIS") posted increased in 2025 over 2024. For OFAC, 2024 was a relatively slow year, and 2025 showed an uptick in numbers of cases. Notwithstanding these increases, OFAC brought big cases involving Russian oligarchs.   For the year, OFAC brought 14 cases and recovered over $265 million in penalties. What was missing, however, was OFAC's steady enforcement against a variety of industries -- the spread of OFAC cases was fairly limited.   From the numbers, for 2025, DOJ indicted, took guilty pleas or participated in sentencing proceedings in a total of forty-one (41) cases. For 26 of these cases, the illegal exports were intended to customers in Russia (16) and China (10); after that, Iran was involved in 5 cases, and Haiti was involved in 4, and Venezuela and North Korea had only 2 cases respectively.   In this Episode, Michael Volkov reviews overall trade enforcement activities for 2025.

    11 min

  4. JAN 12

    Episode 388 -- Anti-Corruption Update with Scott Greytak, Transparency International, and Nate Sibley, Hudson Institute

    Scott Greytak, Transparency International, and Nate Sibley, Hudson Institute, join Michael Volkov for a review of anti-corruption issues and a look forward to the next year.

    47 min

  5. JAN 7

    Tom Fox and Mike Volkov Discuss Compliance Issues in 2025 and Trends for 2026 (Part 2 of 2)

    Tom Fox joins Michael Volkov to discuss ethics and compliance issues for the year 2025. Tom and Mike focus on the importance of ethics, conflict of interest, trade compliance, organizational justice and other issues. This is Part 2 of a 2-Part Episode.

    23 min

  6. JAN 5

    Tom Fox and Mike Volkov Discuss Compliance Issues in 2025 and Trends for 2026 (Part 1 of 2)

    Tom Fox joins Michael Volkov to discuss ethics and compliance issues for the year 2025. Tom and Mike focus on the importance of ethics, conflict of interest, trade compliance, organizational justice and other issues. This is Part 1 of a 2-Part episode.

    20 min
  7. [Replay] Five Strategies to Mitigate a New Risk Environment

    09/08/2025

    [Replay] Five Strategies to Mitigate a New Risk Environment

    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 timesHow to run a quick-turn, focused risk assessment to identify new hotspots like sanctions, tariffs, and supply chain gapsThe rising danger of indirect exposure to foreign terrorist organizations and cartels through third partiesWhat companies need to know about tariff classification, scope, and enforcement to avoid legal and economic penaltiesWhy sanctions and export controls enforcement is heating up—and what that means for your global operationsHow 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

    14 min
  8. [Replay] Third-Party Risks and Sanctions Compliance

    09/01/2025

    [Replay] Third-Party Risks and Sanctions Compliance

    With the beginning of the “New FCPA” era coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just the same as FCPA legal requirements. As we embark on a new criminal enforcement era surrounding sanctions violations, companies have to address this issue and do it correctly.  In this episode, Michael Volkov takes a comprehensive look at third-party risks from the distribution and supply sides and outlines appropriate strategies to manage these risks. Epsilon Electronics serves as a stark reminder of the financial consequences of non-compliance. The company faced an OFAC enforcement action due to a shipment to Iran, resulting in a staggering penalty of over $4 million.Apollo Aviation Group settled with OFAC for $210,600 for leasing aircraft engines which ultimately ended up being placed in to aircraft of a prohibited entity, Sudan Airways, violating sanctions regulations.ELF Cosmetics settled with OFAC for $996,000 for importing false eyelash kits containing materials sourced from North Korea, highlighting supply chain due diligence failures.The ELF Cosmetics case underscores the crucial role of supply chain due diligence in preventing sanctions violations. Instead of sticking their heads in the sand, companies must undertake basic supply chain due diligence when sourcing products from regions close to high-risk countries or regions.“Reason to know” is now the key phrase guiding the New FCPA era. OFAC does not need to prove goods ultimately end up in a sanctioned country. When you see red flags, you must resolve them or they could be considered a “reason to know” in OFAC’s eyes.Seven essential elements to boost your compliance program and effectively mitigate third-party sanctions risks include risk assessment, varying levels of due diligence, end-user documentation, monitoring, training, and red flag identification. Resources Michael Volkov on LinkedIn | Twitter The Volkov Law Group

    19 min
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4.9
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About

Michael Volkov tackles the current and hot topics in the legal realms of corruption, crime, and compliance.

Information

  • Creator
    Michael Volkov
  • Years Active
    2017 - 2026
  • Episodes
    372
  • Rating
    Clean
  • Copyright
    © Copyright 2022 Corruption Crime & Compliance
  • Show Website
    Corruption Crime & Compliance

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