Michael Volkov – The Volkov Law Group


Washington, D.C. , United States

  • (240) 505-1992

Happy Birthday FCPA Guidance

The FCPA Guidance turned two years old recently – November 14 to be exact. No one wrote about the milestone, nor has anyone praised the FCPA Guidance. To be the contrarian, I am writing to wish the FCPA Guidance a very happy…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

The Importance of a Code of Conduct

Companies and Chief Compliance Officers have taken significant actions to emphasize the importance of a company’s code of conduct. A well-designed code of conduct is a foundation for an effective ethics and compliance…more
| Commercial Law & Contracts

A Holistic Look at Third Party Risks

In the FCPA world, we tend to get myopic. We see complex issues and business operations through the prism of anti-corruption risks. Businesses and Chief Compliance Officers, however, have a very different perspective…more
| Commercial Law & Contracts, International Law & Trade

Recent FCPA Enforcement Actions: The Layne Christensen Case and SBM Offshore

The Fourth Quarter of 2014 has been a busy one for DOJ and SEC in the FCPA arena. We are all praying that DOJ and SEC resolve the Avon case soon so that we do not have to include the case on our lists for predictions for 2015…more
| Commercial Law & Contracts, Criminal Law, International Law & Trade, Securities Law

Significant Trends from Recent FCPA Enforcement Actions: The Bio-Rad Case

The FCPA enforcement doomsayers can add another notch to their belt – their predictions and suggestions of “enforcement slow downs,” “significant policy changes,” and other misguided claims can be added to the ash heap of…more
| Commercial Law & Contracts, International Law & Trade, Science, Computers, & Technology, Securities Law

Working in the Compliance Field – The Need for Practical Solutions

With the rise of the compliance professional, there is a real need for strong support as they design and implement new and innovative compliance programs…more
| Commercial Law & Contracts

The Curious World of the Antitrust Division and Credit for Compliance Programs

The Antitrust Division is a world unto itself. Ask anyone who works there (including me) or worked there and they will tell you that everyone refers to the Antitrust Division as “The Division,” like it is the only Division in…more
| Antitrust & Trade Regulation, Commercial Law & Contracts

Voluntary Disclosure: The Continuing Debate

For years (okay 3 years), I have written about the need for DOJ to address its policies surrounding voluntary disclosure. DOJ and the SEC regularly urge companies and FCPA practitioners to disclose FCPA violations to DOJ in…more
| Commercial Law & Contracts, Criminal Law, International Law & Trade

Gratitude and — 1001 Beers on the Wall . . . .

I am not one to contrive milestones. Life is full of important events and we do not need to make up any more. So with humility and more importantly, gratitude, I am marking my 1001 posting on Corruption, Crime & Compliance…more
| Commercial Law & Contracts, International Law & Trade

Culture of Compliance: A Low-Cost Compliance Strategy

Do the right thing. It will gratify some people and astonish the rest – Mark Twain Mark Twain would have been a terrific chief compliance officer. His words would have inspired people, and for those that obstruct rational…more
| Commercial Law & Contracts

A CCO’s Vision Needs to Include “Line of Sight”

With the rise of chief compliance officers, come new terms and concepts. That is a good thing because it represents a maturation and standardization of the profession…more
| Commercial Law & Contracts

Sharing the Spotlight: M&A Due Diligence

Everyone likes to talk about the importance of due diligence. A whole new due diligence industry has grown, starting with initial anti-money laundering requirements and stretching into corruption and sanctions issues…more
| Commercial Law & Contracts, Mergers & Acquisitions, International Law & Trade

The Important Distinction Between Ethics and Compliance

I know that I can be a stickler for details sometimes. Ask my children. Ask my wife. So, when it comes to compliance, I repeat myself often when I remind everyone: it is ethics and compliance, not just compliance…more
| Commercial Law & Contracts

Knowing When to Fold — Arguing the FCPA’s Definition of “Foreign Official”

With lots of fanfare, Esquenazi and Rodriguez, and the usual suspects filed a cert petition and briefs in support of the appeal from the 11th Circuit Court of Appeals’ decision affirming the lower court’s interpretation of…more
| Commercial Law & Contracts, Criminal Law, International Law & Trade

Jodi Arias: Bordering on Death?

Just when we thought Jodi Arias had receded into the shadows of notorious sociopathic killers, she has returned for yet another drama-filled narcissistic replay of her depraved indifference to life and humanity…more
| Criminal Law
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