FinCEN's AML Reform Proposal -- A Shift Toward Risk, Clarity and Innovation

It's tempting to cut ethics and compliance in this time. But that would be a mistake.Ethics and compliance provide important fundamental values that in the end make a company more profitable.They promote employee well-being, employee engagement, and makes sure that employees have a vested interest in their company.This is not the time to start jeopardizing those important values.So keep the message going - ethics and compliance are positive to the revenue bottom line.If ethics and compliance are your passion, we need to talk - reach out at [email protected] Ethics and Compliance Q and A show is produced by One Stone Creative.

FinCEN’s April 2026 proposed rule marks a major shift in AML/CFT compliance by redefining how programs are evaluated, enforced, and managed under the Bank Secrecy Act. In this episode, Michael Volkov breaks down the proposal’s most significant changes, including the new two-pronged framework distinguishing program design from implementation, a higher threshold for enforcement focused on systemic failures, and expanded expectations for risk-based compliance and governance. The rule also encourages the use of innovative technologies like artificial intelligence while requiring stronger board oversight and U.S.-based compliance leadership. With a 12-month implementation timeline and a clear push toward outcome-driven compliance, this proposal signals a fundamental transformation in how financial institutions should approach AML risk management.

Your board thinks compliance is a cost center. Here's the research that proves them wrong and how to make sure they know it.Want help making the case for compliance at the top? Visit volkovlaw.com

Here are 3 more reasons you may think twice about letting ChatGPT run your compliance program.First, content monitoring.The content that you generate through ChatGPT or any AI service can raise real risks with regard to improper intellectual property, data privacy risks where you name certain individuals or name certain identifiers, and most importantly, remember your third-party risks.When it comes to AI, you're using vendors, and those vendors have their own AI policies, and you need to analyze and mitigate those risks as part of the due diligence process and as part of the monitoring process once you've onboarded them.So be careful, take all our six steps and hold them together and mitigate your risks.The Ethics and Compliance Q and A show is produced by One Stone Creative.

Artificial intelligence is rapidly transforming business operations—but it is also introducing a new generation of legal, ethical, and compliance risks. In this episode, we explore how AI risk is accelerating across organizations, from data leakage and bias to over-reliance on flawed outputs and hidden third-party exposure. Drawing on real enforcement trends and practical examples, we explain why AI risk is fundamentally a human and governance issue—not just a technology challenge—and why companies must adopt a risk-based approach that distinguishes between high- and low-risk AI use cases. This episode outlines the core elements of an effective AI compliance program, including governance structures, employee training, vendor oversight, and regulatory readiness in an increasingly scrutinized environment.

Are you actually thinking of turning over your compliance program to ChatGPT? If so, you need to listen to this.AI has to be implemented in a methodical way, a step-by-step program. So let's talk about those steps.First, you need a governance structure, meaning you have to have an organization responsible across the entire organization for all your uses of AI.Second, like every issue that we deal with in ethics and compliance, you need a risk assessment. And you need to look at specific use cases and how those are going to impact your risk profile. This is critical. Only then you can start to tailor your program.Third, you need to decide and investigate what exactly your risks are.Is it algorithmic, meaning you're using it for your business purpose, or non-algorithmic?Stay tuned to part two, and we're gonna talk about the rest of the steps.The Ethics and Compliance Q and A show is produced by One Stone Creative.

In this episode, we examine the Department of Justice’s declination in the Balt Medical case—a textbook example of how DOJ is applying its Corporate Enforcement Policy in practice. Despite a multi-year foreign bribery scheme involving payments to a physician at a state-owned hospital, DOJ declined to prosecute the company based on its timely self-disclosure, full cooperation, and effective remediation. But the real story lies in DOJ’s simultaneous prosecution of two individuals who allegedly orchestrated the scheme, highlighting the central role of individual accountability in earning cooperation credit. This episode unpacks how companies must now “connect the dots” for prosecutors—identifying responsible actors and providing actionable evidence—if they hope to secure favorable outcomes.

In this episode, we break down the sweeping shift in U.S. sanctions policy toward Venezuela following the 2026 political transition and the issuance of multiple new general licenses by the Office of Foreign Assets Control. While the U.S. has opened the door to significant commercial activity—particularly in oil, gas, and minerals—this is not a full lifting of sanctions but a highly conditional framework with strict compliance guardrails. Companies can now engage in transactions involving Venezuelan energy and infrastructure, but must navigate complex restrictions, reporting obligations, and geopolitical limitations, including prohibitions involving Russia, Iran, and China-linked entities. This episode explores the opportunities, risks, and compliance challenges created by this carefully calibrated reopening of the Venezuelan economy.

The final quarter of 2025 produced a modest resurgence in Foreign Corrupt Practices Act (FCPA) activity following the administration’s June 2025 FCPA guidelines. Whether that uptick signals a sustained enforcement trend remains uncertain. But one theme remains clear: individual FCPA enforcement is alive and well.While corporate resolutions may benefit from evolving DOJ policy and a renewed emphasis on negotiated dispositions, individuals continue to face indictment, trial, sentencing, forfeiture, and reputational destruction

In this episode of Corruption, Crime and Compliance, Michael Volkov sits down with entrepreneur and innovator Paul Allen, founder of Ancestry.com and Soar.com, to explore the evolving intersection of artificial intelligence, governance, and public trust. Paul shares insights from his latest venture, CitizenPortal.ai, an AI-powered civic intelligence platform aimed at making government activity more transparent, accessible, and accountable to everyday citizens. The conversation moves beyond hype, focusing on how AI can strengthen—not replace—democratic institutions through constrained, verifiable systems that enhance understanding and engagement. With a thoughtful and pragmatic lens, Paul discusses the risks, opportunities, and responsibilities that come with deploying AI in the public sphere, offering listeners a compelling vision for how technology can rebuild trust in institutions at a critical moment.