Michael Volkov – The Volkov Group Law Firm

The FCPA Paparazzi has been at it again – it is fascinating to watch the reaction of practitioners and commentators in the FCPA arena…more

Hopefully, you and your company will never have to prove to a court or argue to the Justice Department that your anti-corruption compliance program is “effective.”…more

People love to give advice – they love to tell people what to do (and hear themselves talk). In order to be effective, compliance professionals have to be able to “listen.”…more

The Consumer Finance Protection Bureau continues to spread its wings in the enforcement arena. It is an agency born and confined in political controversy…more

Let’s try and put this all in perspective. Last fiscal year, the Antitrust Division collected over $1 billion in criminal fines and sent a number of senior executives to prison…more

Chief Compliance Officers are basically optimists. In the face of a mountain of worst case scenarios (typically referred to as “risks”), CCOs keep smiling and work incredibly hard…more

In the age of superstar CEOs who command media attention and excessive compensation packages, a company’s performance can often boil down to the relationship between the Board and the CEO…more

Chief Compliance Officers are usually very proud of their anti-corruption training programs. Most companies rely on a combination of live and on-line training programs to communicate the message of compliance…more

Every compliance program depends on collaboration. No one actor at a company determines the success or failure of a corporate compliance program…more

There is a lot of grumbling these days over the Justice Department’s use of Deferred and Non-Prosecution Agreements. Some think the deals are too lenient and corporations should be required to plead guilty. Capitol Hill…more

The bottom-line: If you do not conduct a risk assessment, then you should start praying. The FCPA Guidance made it clear – conduct a risk assessment and tailor your compliance program to the risk assessment…more

As the Jodi Arias criminal trial winds down, I have to go out on a limb and make my prediction…more

Hospitals continue to be under the Department of Justice-HHS/Office of Inspector General microscope. DOJ-OIG is a potent combination and carry with them the threat of criminal prosecution, civil false claims enforcement and…more

The Justice Department and the SEC should be credited with promoting new compliance strategies and best practices. Whatever you may think about the DOJ/SEC FCPA enforcement program, they have pushed businesses to enhance their…more

Every company has its share of internal politics, rivalries and tensions. No organization is free from internal strife. For a company to be successful, you need talented, ambitious and intelligent people…more