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If your sanctions program is still the 2019 version, it’s missing the last seven years of enforcement.
OFAC’s 2019 framework is still your foundation: management commitment, risk assessment, internal controls, testing, and training. But DOJ, Commerce, and Treasury have layered new expectations on top of that through joint Tri-Seal Notes.
Four of them shou...
The Adani prosecution has become one of the most closely watched corruption cases in the country, and not because of the facts alleged in the indictment. It is now a contest over a narrower and more consequential question: when the Justice Department decides it no longer wants to pursue a criminal case, how much of an explanation does a federal court get to demand? On Se...
AI is not coming to your company. It is already there. Employees are drafting emails, summarizing contracts, writing code and analyzing data with AI tools today, many on personal accounts the company never approved. If your organization does not have a responsible AI use policy, you do not have an AI strategy. You have an AI exposure.
The Risk Is Not Theoretical ...For years, a healthcare company that discovered possible wrongdoing faced two questions at once: should we tell the government, and which part of the government should hear it first? On October 15, 2026, the Justice Department’s National Fraud Enforcement Division and the Department of Health and Human Services Office of Inspector General answered the second question wit...
In this episode of Corruption, Crime and Compliance, Michael Volkov examines the more than $1.21 billion in Treasury penalties announced October 13, 2026 against Bank of America, including FinCEN’s $1.2 billion consent order, which credits the OCC’s record $750 million penalty and includes the bank’s admission that it willfully violated the Bank Secrecy Act. Volkov expla...