Michael Volkov – The Volkov Group Law Firm

Mitigating Bribery Risks With Financial Controls

Anti-corruption compliance is not as hard as it looks. In fact, by taking a step back, compliance professionals can gain insights. At the direction of compliance professionals, companies like to develop and adopt…more

| Commercial Law & Contracts, International Law & Trade

AML Enforcement And Sanctions

AML enforcement often includes sanctions violations. The Office of Foreign Asset Control (OFAC) is responsible for regulating and enforcing the sanctions regime…more

| Commercial Law & Contracts, Finance & Banking, International Law & Trade

A Close Look At Internal Controls

Companies with ineffective internal controls face risks of embezzlement and self-dealing by employees, bribery, export control violations and other possible legal violations. The payment of foreign bribes often occurs in…more

| Commercial Law & Contracts, International Law & Trade

To Be a Criminal, You Have to Act Like a Criminal

Lawyers, compliance professionals and senior management at companies can be obsessive when it comes to the threat of criminal liability. Please do not get me wrong, I am not minimizing the risk of criminal prosecution, nor I am…more

| Commercial Law & Contracts, Criminal Law

Paper Tigers And Paper Compliance

The FCPA Guidance is an extraordinary document filled with excellent ideas, defined safe harbors and important enforcement and compliance principles. It is a lesson in good government, and a testament to an instructive process…more

| Commercial Law & Contracts, International Law & Trade, Securities Law

AML Enforcement Jitters And Due Diligence

The Justice Department and the financial regulatory agencies have sent a strong message of enforcement, suggesting that financial institutions are not adequately implementing AML compliance controls…more

| Commercial Law & Contracts, Finance & Banking, International Law & Trade

Corruption Continues To Eat Away At India

At first glance, India is a country of incredible economic opportunity. India’s GDP is slated to continue to grow five (5) percent each year. It has the third biggest economy in the world, below the US and China…more

| Commercial Law & Contracts, International Law & Trade

Do Compliance Professionals Have To Be Lawyers?

As compliance professionals enjoy the rise of their profession, lawyers are sensing a decline in importance. I am hearing from compliance professionals a new and disturbing trend – companies are requiring compliance…more

| Commercial Law & Contracts

Digging Down on Joint Ventures and FCPA Compliance

The FCPA is a broad statute. As written, it covers a number of situations, and creates twists and turns in analysis. One of the more challenging areas to navigate is the issue of joint ventures. When you bring two…more

| Commercial Law & Contracts, International Law & Trade

The Economic Crime Triad: Companies Facing Major Risks

FCPA practitioners can suffer from myopia – a narrow focus on FCPA risks. The FCPA does not apply to company actors who take bribes in exchange for awarding contracts to companies. That situation is commonly referred to as…more

| Commercial Law & Contracts, Criminal Law, International Law & Trade

CCO’s Be Careful What You Ask For — You Just May Have It

The old adage has taken hold in the compliance field – “Be careful what you ask for, you just may get it.” Compliance professionals are finally getting the respect they deserve. They still have a long way to go. General…more

| Commercial Law & Contracts

Alstom: The Next Poster Child For Anti-Corruption Enforcement

You can learn a lot from other people’s mistakes. We all know that. In our FCPA world, we have a new poster child for blundering – Alstom. The handwriting is on the wall – as time goes on, the Justice Department is…more

| Commercial Law & Contracts, International Law & Trade

Encouraging Communication Of Employee Concerns

One of the hardest issues for compliance professionals is encouraging employees to raise concerns about ethics and compliance issues. It has become even more difficult when the government establishes whistleblower programs…more

| Commercial Law & Contracts, Labor & Employment Law

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