Michael Volkov – The Volkov Law Group

Tenet Healthcare Settles Fraud Case for $514 Million

If you work in compliance in the healthcare industry, you have a tough job. The number and variety of risks that healthcare providers face is daunting. The False Claims Act is a mighty weapon in the hands of federal prosecutors…more
| Commercial Law & Contracts, Government Contracting, Health

When Business Supersedes Compliance – A Recipe for Disaster

When looking through the wreckage of a major corporate compliance disaster, it is relatively easy to spot the important events when business needs (or money) are consciously elevated over compliance concerns or even reputational…more
| Commercial Law & Contracts

A New and Significant Anti-Corruption Voice in the Ukraine

The anti-corruption field has the benefit of many great leaders, bloggers, academics, researchers, NGOs and other contributors who are committed to the battle against corruption.  Many people dedicate themselves with little to…more
| Commercial Law & Contracts, International Law & Trade

DOJ Criminal Prosecution of Wells Fargo: What to Expect?

Compliance and enforcement headlines have focused on the Wells Fargo scandal. And for good reason. On September 8, 2016, the Consumer Financial Protection Bureau, the Comptroller of the Currency and the Los Angeles County…more
| Commercial Law & Contracts, Finance & Banking

DOJ and SEC Raising the Stakes on Third Party Risk Management

If you review the last ten years of FCPA enforcement, the unmistakable pattern is rising expectations with regard to corporate compliance programs, particularly with regard to third party due diligence and risk management. Over…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

After Circling the Wagons: Wells Fargo’s CEO Finally Falls

The Wells Fargo scandal represents a textbook case of compliance and culture failures. Recently, the scandal and Wells Fargo’s defensive crisis management strategy resulted in CEO Stumpf’s resignation. Stumpf’s demise was…more
| Commercial Law & Contracts, Finance & Banking, Consumer Protection

Och-Ziff: Accountability and Internal Controls (Part IV)

There are a number of important lessons from the Och-Ziff enforcement action, some of which are related to the private equity and hedge fund industry and some of which apply across all businesses…more
| Commercial Law & Contracts, International Law & Trade

FCPA Enforcement Ramping Up Against Private Equity and Hedge Funds (Part III)

The Och-Ziff settlement has now set the stage for the Justice Department and the SEC to focus its enforcement eye on the private equity and hedge fund industry. The Och-Ziff action was initiated in response to the SEC’s industry…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Och-Ziff Failures in Due Diligence and Transaction Compliance (Part II)

The Och-Ziff enforcement action is replete with examples of failures in due diligence and transaction monitoring compliance. Och-Ziff’s bribery schemes were elaborate and intricate and involved complex transactions, particularly…more
| Commercial Law & Contracts, International Law & Trade

DOJ and SEC Deliver Body Blow to Private Equity and Hedge Funds: Och-Ziff Settles FCPA Violations for $412 Million (Part I)

The Justice Department and the Securities Exchange Commission delivered a powerful FCPA enforcement message to private equity and hedge funds. Och-Ziff settled with the DOJ and SEC for total penalties of $412 million…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Securities Law

The Recalibration of Compliance: What is the Definition of Success?

We often hear a chorus of criticism relating to the compliance function. How do you define success? Some of this is the result of a political backlash. Chief compliance officers are the darlings in the corporate governance…more
| Commercial Law & Contracts

GSK Settles SEC FCPA Case for $20 Million

The SEC finished with the last nail in GSK China’s coffin by announcing a $20 FCPA million settlement for GSK’s violations in China. The Justice Department declined to prosecute this case. In 2014, a Chinese court fined…more
| Commercial Law & Contracts, Health, International Law & Trade, Science, Computers, & Technology

Double Play, Double Declinations: DOJ Pushes FCPA Pilot Program Benefits

DOJ’s FCPA Pilot Program was panned when it was announced in April 2016. Critics contended that the incentive for voluntary disclosure of FCPA violations to DOJ was inadequate…more
| Commercial Law & Contracts, Energy & Utilities, International Law & Trade

5 Key Takeaways from AB InBev SEC FCPA Settlement

The Justice Department and the SEC have been busy over the last 2 weeks in the FCPA arena. For those who have raised doubts about DOJ and the SEC’s continuing commitment to FCPA enforcement, you should forever hold your peace…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Dig a Little Deeper: The Importance of Beneficial Ownership

Companies interact with a large number of entities in the outside world – customers, third party intermediaries and vendors and suppliers to name the most significant ones. These relationships are the lifeblood of a company…more
| Commercial Law & Contracts, International Law & Trade
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Washington, D.C. , United States

  • (240) 505-1992

Areas of Practice
  • Antitrust & Trade Regulation
  • Criminal Law
  • Energy & Utilities
  • Finance & Banking
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  • International Law & Trade
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  • Mergers & Acquisitions
  • Securities Law
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