Michael Volkov – The Volkov Law Group

Coordinating Third Party Due Diligence and Procurement

Third party risk management is easily one of the most challenging risks for compliance officers. With all the attention and hype surrounding third party risk, companies have marshaled attention and resources to mitigate the risk…more
| Commercial Law & Contracts, International Law & Trade

Aggressive Remediation: Embraer and JP Morgan

There is no question that the Justice Department has raised compliance program expectations in a number of areas. Whatever you may think about the efficacy or fairness of the FCPA Pilot Program, the Justice Department has…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Science, Computers, & Technology

Two Executives Charged in Valeant Pharmaceuticals Criminal Investigation

Two executives were charged last week with criminal violations in the Southern District of New York relating to Valeant Pharmaceuticals activities. These charges are the first of more to come in an ongoing investigation focusing…more
| Commercial Law & Contracts, Criminal Law, Science, Computers, & Technology

Conflict of Interest Issues – A Significant Risk

In the risk mitigation business, we often focus on legal risks, such as anti-corruption, sanctions, export controls, antitrust and AML. As compliance programs mature, and the CCOs focus on proactive strategies, one key issue is…more
| Commercial Law & Contracts

Lessons Learned From FCPA Enforcement Against JP Morgan for Sons and Daughters Referral Program

Last week, the Justice Department and the SEC finally brought to a close the Sons and Daughters or Princelings investigation. Pending investigations against four other companies still remain to be resolved…more
| Civil Remedies, Commercial Law & Contracts, Finance & Banking, International Law & Trade

The Myths Surrounding Ethics and Compliance Programs

Chief compliance officers have a difficult job. That is a real profound grasp of the obvious. CCOs face an unending onslaught of tasks, risks and juggling of concerns and activities. On many respects, a CCO’s job is never done –…more
| Commercial Law & Contracts

When Your Internal Investigator Fails to “Investigate”

A number of recent FCPA enforcement actions have cited common compliance program failures relating to internal investigations. For example, PTC settled FCPA charges with the DOJ and SEC for $28 million. According to the factual…more
| Commercial Law & Contracts, International Law & Trade

Super Moon Harkens Low Tide for Hatch-Waxman Patent Disputes

This week, the U.S. Supreme Court denied a petition for writ of certiorari in a case that will give pharmaceutical companies pause when considering whether to settle patent challenges under Hatch-Waxman. The Supreme Court’s…more
| Civil Procedure, Commercial Law & Contracts, Intellectual Property, Science, Computers, & Technology

Do You Know and Understand Your Compliance Policies?

My question appears to be fairly obvious, right? This is not a question or a quiz of every chief compliance officer. Rather, this is a question for everyone but the CCO and compliance and legal staff. Think about it. Does…more
| Commercial Law & Contracts, International Law & Trade

Infusing Your Compliance Program with Business Ethics

It is important to remember that companies are required to implement an ethics and compliance program. Ethics should not ever be a segregated issue carved off from a compliance program. They walk hand-in-hand, and reinforce each…more
| Commercial Law & Contracts, International Law & Trade

When Tone at the Top Is Missing

We all tend to gloss over a critical requirement for an effective ethics and compliance program – tone-at-the-top. I hate to be dogmatic about the issue but, as Mel Brooks said in the Curb Your Enthusiasm (Season 4, Episode 1),…more
| Commercial Law & Contracts

A New Administration: A New FCPA Enforcement Regime?

Now that the dust has settled on this turbulent campaign season, everyone is in the prediction game, especially when it comes to FCPA enforcement. It is easy to make predictions of significant change. It is easy to take campaign…more
| Commercial Law & Contracts, Communications & Media Law, Elections & Politics, Mergers & Acquisitions, International Law & Trade

Due Diligence Basics – Beneficial Ownership

I hate to be the harbinger of bad news; that is against my nature; I am naturally an optimistic person. As I always say, there are solutions to every problem…more
| Commercial Law & Contracts, International Law & Trade

Making Sure Business Ethics Has a Seat at the Table

Everyone likes to cite and talk about the list of horrible scandals. Whether it is Enron, WorldCom, Siemens, GM, VW, Wells Fargo, we pick through the details, cite failures and use it as a springboard to a discussion of higher…more
| Commercial Law & Contracts, International Law & Trade

AAG Caldwell Touts Success of FCPA Enforcement and Pilot Program

In a speech last week, Criminal Division Assistant Attorney General Leslie Caldwell touted the success of the FCPA Pilot Program. AAG Caldwell outlined the success of the FCPA enforcement program, listing many of the most…more
| Commercial Law & Contracts, International Law & Trade
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Contact


Washington, D.C. , United States

  • (240) 505-1992

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