Michael Volkov – The Volkov Law Group

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

FCPA Books and Records and Internal Controls Enforcement – A Retrospective (Part III of IV)

Plan for the future because that’s where you are going to spend the rest of your life. – Mark Twain. The SEC enforces its books and records and internal controls provisions, most of which involve non-FCPA violations…more
| Administrative Law, Commercial Law & Contracts, International Law & Trade, Securities Law

Internal Accounting Controls – The Framework for Enforcement (Part II of IV)

When you review the actual law surrounding books and records and internal controls, you wonder to yourself what took the Justice Department and the SEC so long to discover the full power of the provisions…more
| Commercial Law & Contracts, Criminal Law, International Law & Trade, Securities Law

Internal Controls Enforcement (Part I of IV)

I was recently inspired by Tom Fox’s excellent writings on the COSO 2013 framework, and his examination of internal controls issues – see here, here, and here. Today, I begin my own series on internal controls but from a…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

DPAs and “Reforming” Corporate Criminal Liability

The controversy surrounding Deferred Prosecution Agreements (“DPAs”) and Non- Prosecution Agreements (“NPAs”) continues to boil. In response to continuing criticism that the Justice Department is using DPAs and NPAs to…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Corporate Branding and Ethics and Compliance Charters and Policies

There is a lot written on the value of symbols in political and public relations campaigns. My favorite President, Franklin Roosevelt, was a master at using symbols to communicate powerful ideas to the public…more
| Business Organizations, Commercial Law & Contracts

Compliance Program Effectiveness Requires Accountability

A compliance program requires accountability. You can have ethics and you can have compliance policies, procedures and all the bells and whistles, but someone has to be accountable…more
| Commercial Law & Contracts
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Washington, D.C. , United States

  • (240) 505-1992

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