Michael Volkov
The Volkov Law Group

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Washington, D.C., United States
Phone: (240) 505-1992
Areas of Practice
  • Antitrust & Trade Regulation
  • Criminal Law
  • Energy & Utilities
  • Finance & Banking
  • Government
  • International Law & Trade
  • Litigation
  • Mergers & Acquisitions
  • Securities Law

The Strange Case of OFAC Against Exxon for Sanctions Violations

In a bizarre enforcement action, The Treasury Department’s Office of Foreign Asset Control (“OFAC”) assessed a $2 million civil monetary penalty against ExxonMobil (“Exxon”) for violations of the Ukraine sanctions…more
 /  Elections & Politics, Energy & Utilities, International Law & Trade

Is Your Company At-Risk for a Government Enforcement Action?

For some reason, I have always believed that picking successful stocks should not be very difficult. Unfortunately, my record in the stock market does not back up my self-assessment. On the other hand, when it comes to…more
 /  Commercial Law & Contracts, International Law & Trade

Should You Record Internal Investigation Interviews?

As a former federal prosecutor, I noticed a renewed discussion of the important question of whether witness interviews should be recorded (either audio or video). I have always found this issue to be interesting and have…more
 /  Commercial Law & Contracts, International Law & Trade

United States v. Nixon – An Important Reminder

In these days of political turmoil, it is always important to know specific and relevant events from our country’s past. I was fascinated by the Watergate scandal and was enamored with the role played by prosecutors and…more
 /  Commercial Law & Contracts, Elections & Politics

Important Polling Results from BVD Webinar on Beneficial Ownership

On July 5, 2017, Bureau Van Dijk, a sponsor of my blog, conducted a webinar on the importance of beneficial ownership information to corporate compliance functions…more
 /  Commercial Law & Contracts, International Law & Trade

CCO’s and Delusions About a Company’s Ethical Culture

It is easy to say something and convince yourself it is true. As George Costanza advised Jerry Seinfeld when Jerry had to take a polygraph examination when he failed to admit that he watched “Melrose Place,” “Remember Jerry. …more
 /  Commercial Law & Contracts, International Law & Trade

“Too Important to Jail,” the Yates Memorandum and FCPA Criminal Prosecutions

The Justice Department’s continuing lack of individual criminal prosecutions in the FCPA arena continues to raise serious questions. DOJ’s issuance of the Yates memorandum was seen as a new and important reiteration of DOJ’s…more
 /  Commercial Law & Contracts, International Law & Trade

DOJ’s “Filip” Factors and Corporate Prosecutions

Companies that experience a Justice Department criminal investigation undergo a long and painful process. DOJ prosecutors hold the cards when reviewing the facts and deciding whether to indict a company…more
 /  Commercial Law & Contracts, International Law & Trade

Criminal Prosecutions of Individuals Outside the FCPA

When you look outside the FCPA arena and examine DOJ criminal prosecutions in healthcare, antitrust, tax, fraud, and other white-collar areas, there is no shortage of cases against individual violators. I am perplexed, to say…more
 /  Commercial Law & Contracts, International Law & Trade

Justice Department Resolves Two Cases Under FCPA Pilot Program

The Justice Department recently resolved two separate FCPA investigations under its Pilot Program. To be sure, DOJ’s resolution of these two matters reinforces the real and tangible benefits of its Pilot Program…more
 /  Commercial Law & Contracts, International Law & Trade

Will the Justice Department Continue to Use DPAs and NPAs?

With a new administration at the Department of Justice, practitioners and commentators are looking for signs of change. Given the current politics of the new administration, the Justice Department will undergo changes in civil…more
 /  Commercial Law & Contracts, International Law & Trade

The Importance of Compliance Program Audits

Chief compliance officers spend a significant amount of time comparing their compliance programs with other companies’ programs. CCOs often find solace when benchmarking their respective programs against other companies’…more
 /  Commercial Law & Contracts, International Law & Trade

Working in a “Happy Talk” Corporate Culture

Honesty is the best policy – when there is money in it. – Mark Twain - Compliance professionals encounter a diverse range of corporate personalities in their work. To be sure, compliance officers have to rely on their…more
 /  Commercial Law & Contracts, International Law & Trade

Poor Performing CEOs and Boards and Compliance Disasters

The business headlines are filled with the latest corporate scandal – Uber’s defective culture, CEO misconduct and reprehensible comments by supervising board members. Uber is just one of several significant companies caught in…more
 /  Commercial Law & Contracts, International Law & Trade

CCOs and Resources: Put Your Money Where Your Mouth Is!

The compliance profession is enjoying its moment of triumph. Chief compliance officers are earning substantial salaries and rewarded with high-level positions in the C-Suite and significant influence. CCOs are the hot…more
 /  Commercial Law & Contracts, International Law & Trade
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