LRN's 2025 Compliance Program Effectiveness Report
Are you running a compliance program that’s making a real impact—or just checking the boxes? In this episode, Michael Volkov dives into LRN’s 2025 Program Effectiveness Report, an annual benchmark that separates the truly impactful compliance programs from those that are merely operational. Based on insights from 1,500 global ethics and compliance professionals, this year’s report draws a clear line between high-impact and medium-impact programs—and what it takes to bridge the gap. The conversation highlights urgent risks, cultural disconnects, and the strategic value of automation, data, and leadership alignment in shaping tomorrow’s compliance functions.You’ll hear him discuss:How high-impact programs are defined by their strategic use of automation, data analytics, and benchmarking tools to drive measurable compliance outcomesWhy third-party risk management—including due diligence and supply chain oversight—is a defining trait of the most effective programs todayThe growing trust gap between Gen Z employees and middle managers, and why this generational shift poses a cultural red flagThe continued dominance of outdated internal systems, regulatory complexity, and budget pressure as top operational challenges facing compliance leadersHow high-impact programs are integrating AI into both their codes of conduct and employee training, preparing teams for emerging tech risksWhat medium-impact programs can do to evolve: focus on training, automation, and peer collaboration to elevate impact and resilienceResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
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11:37
Global Anti-Corruption Round Up
When The United States has hit pause on Foreign Corrupt Practices Act (FCPA) enforcement—it left many asking whether Europe will now be stepping up to lead the global anti-corruption charge. In this episode of Corruption, Crime and Compliance, Michael Volkov explores how European prosecutors are responding to the enforcement gap, why multinational companies can’t afford to slow down their compliance efforts, and how both state-level and international initiatives are reshaping the future of anti-bribery law.You’ll hear him talk about:The launch of a new International Anti-Corruption Prosecutorial Task Force formed by the UK, France, and Switzerland, designed to intensify cross-border enforcement and cooperation in bribery and corruption cases.The task force’s formation as a direct response to the U.S. enforcement pause, signaling that European agencies are prepared to take a more prominent role in prosecuting international corruption, especially involving multinational corporations.California’s bold move to pursue foreign bribery under its Unfair Competition Law (UCL), reinforcing that FCPA violations remain prosecutable at the state level despite federal hesitation.A continued commitment by global companies to maintain strong compliance programs, reflecting awareness that international and local enforcement can still pose serious legal and financial risks.The unexpected dismissal of the long-running FCPA case against Cognizant executives, contrasted with the DOJ's decision to move forward with prosecutions in other high-profile cases, suggesting a selective enforcement pattern under current policy shifts.A landmark case by the UK Serious Fraud Office (SFO), charging a company with failure to prevent bribery—a first for the SFO to bring such a case before a jury, potentially setting a new standard for corporate liability in the UK.ResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
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12:10
DOJ Issues Data Security Program Requirements
Could your routine data transfers now violate federal law? The DOJ’s new Data Security Program (DSP) targets the flow of U.S. sensitive personal and government data to foreign adversaries — and the clock is ticking. In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down the Justice Department’s sweeping new Data Security Program, enacted under Executive Order 14117 and finalized in January 2025.You’ll hear him discuss:The origins of the DSP, created through Executive Order 14117 under the Trump Administration, and the key national security concerns it addresses.What constitutes a “covered data transaction” and the thresholds for U.S. personal and government data that trigger compliance obligations.The list of “countries of concern” and what it means for companies doing business with entities tied to these regions.The types of U.S. data covered by the DSP, including biometric, genomic, financial, and geolocation data, and the specific quantity thresholds that trigger restrictions.Why data brokerage and bulk human genomic data transactions are prohibited outright, raising new compliance challenges for affected industries.How “restricted transactions” like cloud computing services and vendor agreements are subject to conditional exceptions under the DSP.The critical actions U.S. companies must take during the 90-day enforcement hiatus, including vendor assessments, renegotiations, and compliance system updates before the July 8th deadline.ResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
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19:17
[Replay] Four Sanctions Cases That Everyone Should Know
How prepared is your organization to handle the evolving landscape of sanctions compliance? In this episode of Corruption, Crime and Compliance, Michael Volkov dives into critical sanctions compliance cases and their implications for global companies. He discusses four significant cases that underscore the necessity of robust compliance programs, particularly in light of increased DOJ enforcement actions. Through these examples, he breaks down the consequences of third-party liability, supply chain risks, and the dangers of inadequate compliance measures, offering valuable insights into how companies can proactively avoid similar pitfalls.Cases discussed:British American Tobacco (BAT): The company faced a staggering $629 million settlement for circumventing North Korean trade sanctions. This case illustrates how corporate prosecutions are evolving to resemble Foreign Corrupt Practices Act (FCPA) cases, emphasizing the growing scrutiny on multinational corporations.Epsilon Electronics: This case clarifies the liabilities companies face when third-party distributors divert products to prohibited countries, such as Iran. Even if the company had no direct involvement in the diversion, it still bears responsibility, underscoring the importance of diligent monitoring of distribution channels.ELF Cosmetics: The company received a $1 million fine for importing goods containing materials sourced from North Korea. This case underscores the critical importance of conducting thorough supply chain due diligence to ensure compliance with international sanctions.Murad LLC: This case focuses on post-acquisition compliance failures, demonstrating the urgent need for thorough pre- and post-acquisition audits. These audits are essential to uncover potential sanctions violations and ensure that newly acquired companies adhere to compliance standards.Resources:Michael Volkov on LinkedIn | TwitterThe Volkov Law GroupLinks to the four cases: British American Tobacco | Epsilon Electronics I Elf Cosmetics | Murad LLCA Framework for OFAC Compliance Commitments (May 2019)
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21:06
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 structuresResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
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