Michael Volkov – The Volkov Law Group

Questioning Prosecutorial Discretion

Prosecutors have taken a few lumps lately. Based on my own experience, most prosecutors are dedicated, hard-working, public servants who are committed to “doing the right thing.”…more
| Commercial Law & Contracts, Criminal Law, International Law & Trade

FCPA Enforcement – Watching the Enforcement River Flow

FCPA investigations are complex, time-intensive and far-reaching. They take time and resources. DOJ and the SEC have been criticized lately for failing to move their cases in a timely fashion. Criminal Division AAG Leslie…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Implementing an Effective Third Party “Audit” Program

We all have our favorite episodes and scenes from the Seinfeld series. As we grow older, we like to reference them more and more – maybe because it reminds us of your “youth” (looking back, my 30s were certainly younger than my…more
| Commercial Law & Contracts, Securities Law

Improving Board Performance: Scrap the Old Model

Corporate boards are under intense scrutiny – shareholder organizations are challenging boards in an attempt to improve board performance. Government prosecutors are focusing more on board responsibility for corporate…more
| Commercial Law & Contracts

Code of Conduct Enforcement

The bulk of company internal investigations are devoted to human resource and code of conduct violations. Of course, there are always potential legal violations but these are far smaller in number but could have disastrous…more
| Commercial Law & Contracts, Labor & Employment Law

Brazil Bribery Scandal Reaches Advertising Agencies

Humans are good at avoidance and can even reach a state of blatant disregard. The corruption news coming out of Brazil is so far-reaching that it is almost numbing…more
| Commercial Law & Contracts, Communications & Media Law, International Law & Trade, Securities Law

How to Ensure the Right Tone at Every Level?

Everyone knows the mantra – yes, we need tone at the top, but we also need tone in the middle and tone at the bottom. Every aspect of this statement, however, requires more work than everyone thinks. Tone at the top is…more
| Commercial Law & Contracts

A Neglected Compliance Task: Program Assessments

The secret of life is honesty and fair dealing. If you can fake that, you’ve got it made. – Groucho Marx - Sometimes compliance practitioners miss the forest from the trees. They can get lost in the details of their…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Lions and Tigers and Bears – Certifications, Checklists and Standards

The compliance profession continues to rise in importance. Companies are paying more attention to corporate culture and devoting resources to enhance existing compliance operations. This approach is reinforced with each week as…more
| Commercial Law & Contracts

Beneficial Ownership and AML, Sanctions and Anti-Corruption Compliance

Sometimes compliance realities outpace enforcement and regulatory requirements. When it comes to FinCEN’s proposal to implement a beneficial ownership rule for financial institutions, global financial institutions do not need to…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade

The Two Ps of Compliance: Promote and Protect

I often complain about compliance messaging. Compliance officers have to be careful to avoid becoming viewed as “nattering nabobs of negativism,” as former Vice President Spiro Agnew famously stated about the liberal media…more
| Commercial Law & Contracts, International Law & Trade

Dancing on a Wire: Audit Committee Oversight of a Company’s Compliance Program

There are many interdependent pieces of a compliance program; if one function fails, the effectiveness of a compliance program can be seriously threatened…more
| Commercial Law & Contracts

The Empowerment of the CCO: Old Ways Die Hard

The compliance profession continues to evolve and grow. More lawyers and law students are seeking knowledge and training in the field of ethics and compliance. There is a reason for that…more
| Commercial Law & Contracts

The Importance of Conflicts of Interest Compliance

A company’s character includes avoiding the appearance of, or actual, conflicts of interest. Compliance professionals need to pay more attention to conflicts of interest. In some instances, companies have not even adopted…more
| Commercial Law & Contracts

The Value of a Vigilant Internal Audit Program

I hate to write a negative column. It is contrary to my nature and perspective. It is easy to complain. It is far more difficult to come up with practical solutions…more
| Commercial Law & Contracts
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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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