Michael Volkov – The Volkov Law Group

Ten Key Elements of an AML Compliance Program

AML compliance reminds me of a classic Three Stooges scene from A Plumbing We Will Go – Curly, as one of the plumbers, continues to add pipes to a leaking bathtub, only to be surprised when the water continues to come out of the…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade

The Purpose of Compliance: Promoting a Positive, Not Preventing a Negative

One thing about maintaining a blog – you have nightmares (alright something a little less than that) about consistency in writing. All of us can be accused of having “evolving” positions, so maybe that is my rationalization…more
| Commercial Law & Contracts

3 Ways to Improve Compliance Training

As the compliance profession matures and evolves, the elements of an effective compliance program follow a similar pattern. Compliance training programs have become more sophisticated over the last five years, as regulators…more
| Commercial Law & Contracts, International Law & Trade

Leveraging a Global Compliance Network

Multinational companies cannot employ and maintain a sufficient number of dedicated compliance staff to ensure the effectiveness of an ethics and compliance program. That is a reality and we all know that is true…more
| Commercial Law & Contracts, International Law & Trade

Refining a CCO’s Reporting Relationship to a Corporate Board

You can observe a lot by just watching – Yogi Berra There is way too much time being spent on esoteric arguments about corporate board reporting responsibilities for Chief Compliance Officers. Let’s agree and move on to…more
| Commercial Law & Contracts

4 Signs of a Weak Culture of Compliance and Ethics

We all know the importance of promoting a culture of compliance and ethics. The benefits of an ethical culture are substantial and worth every penny of investment in creating and promoting such a culture. We do not need to spend…more
| Commercial Law & Contracts

Rolling the Dice: Casinos, FinCEN and AML Compliance

FinCEN has many important responsibilities but one of its more interesting assignments is oversight of anti-money laundering compliance by casinos (and card clubs). Casinos are under increasing scrutiny these days for lax AML…more
| Art, Entertainment, & Sports Law, Commercial Law & Contracts, Finance & Banking, International Law & Trade

Scrutinizing Third-Party Payments

It is often hard to convince people that receiving money can be a problem. Everyone likes to receive money, especially when they are being paid for something they did. In the area of compliance priorities, companies do not…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade

Private Equity FCPA Enforcement

FCPA enforcement efforts are not so hard to follow and predict – the government likes to provide advance warnings as an effective means of deterrence. Justice Department and SEC officials will often tell the public their views…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Know Your Customer (“KYC”) Due Diligence Best Practices

Financial institutions have a lengthy list of Anti-Money Laundering compliance requirements. They face a mountain of risks from a large number of financial transactions, each of which can carry significant risks. AML…more
| Commercial Law & Contracts, Finance & Banking

AML Risk Assessments

I am a strong proponent of conducting a risks assessment as part of an overall ethics and compliance program. However, I often caution companies to balance benefits and costs, and not to conduct a glitzy, high-priced risk…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Securities Law

AML Risks and Compliance for Non-Financial Institutions

Consider yourself lucky if you work at a company that does not fall within the Title 31 of the US Code definition of a “financial institution.” I am being somewhat dramatic but it is important for every company to have an…more
| Commercial Law & Contracts, International Law & Trade

The Sigelman Case and DOJ’s FCPA Trial Record

In the aftermath of the Sigelman FCPA criminal trial, the FCPA Paparazzi is in full force hyperventilating about “trends,” “messages,” and “lessons learned.” As a former prosecutor with plenty of trial experience (over 75…more
| Commercial Law & Contracts, International Law & Trade

Shining a Light on Corporate Boardrooms and the Absence of Diversity

Some things are really clear in life – everyone knows something has to change but no one acts. Maybe it goes back to a common theme in corporate cultures – an unwillingness to stand out and instead rely on silence or what some…more
| Commercial Law & Contracts

The Important Distinction Between Legal and Business Ethics

We all know the jokes about lawyers – I have to repeat just one of them: Q. Why won’t sharks eat lawyers? A. Professional courtesy. The Chief Legal Officer is a vital player in a corporate compliance program. There is…more
| Business Organizations, Commercial Law & Contracts
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