Michael Volkov – The Volkov Law Group

Healthcare Compliance Programs to Avoid a False Claims Act Case

You can always count on lawyers to ring alarm belles and warn businesses. The line between accurate reporting and fear-mongering sometimes blurs when lawyers write so-called “alerts” to inform businesses of new or increasing…more
| Commercial Law & Contracts, Government Contracting, Health

Gifts, Meals and Prosecution: BHP Billiton’s Settlement

The SEC is on a mission – companies that engage in egregious payment schemes for gifts, hospitality and travel are going to get prosecuted for civil FCPA violations. Recent SEC enforcement actions against companies continue, and…more
| Administrative Law, Commercial Law & Contracts, International Law & Trade, Securities Law

Tea Leaves from AAG Caldwell on An Effective Compliance Program

The government is on a public relation campaign. Department of Justice and SEC officials have been making the rounds and giving important speeches on criminal prosecutions, cooperation and voluntary disclosure and ethics and…more
| Commercial Law & Contracts, International Law & Trade

4 Questions to Ask When You Learn of Potential FCPA Violation

You can add this blog posting to my tagged category – “profound grasps of the obvious.” If you are brave and willing to succumb to yet another in this series, please read on. Much has been written about how to conduct an…more
| Commercial Law & Contracts, International Law & Trade

The Future of Corporate Criminal Prosecutions (Part IV of IV)

DOJ has developed a new and innovative model for criminal prosecution of corporations. The jury is still out on whether this model is the best use of public resources. DOJ frequently touts its successes based on criminal…more
| Administrative Law, Commercial Law & Contracts, International Law & Trade

Can a Corporation Survive a Criminal Conviction? (Part III of IV)

In my continuing series on corporate criminal prosecutions, an important assumption for many DOJ policies and corporate counsel representation is that a company cannot survive a criminal conviction…more
| Administrative Law, Business Organizations, Commercial Law & Contracts

DOJ Criminal Investigations: “Boiling the Ocean” and Other Fish Tales (Part II of IV)

The old maxim – “Justice delayed is justice denied” – is a powerful statement relating to our criminal justice system. A subject of a criminal investigation – corporate or individual — undergoes enormous stress from a continuing…more
| Administrative Law, Commercial Law & Contracts, Constitutional Law, International Law & Trade, Securities Law

The (Relatively) “New” Model for Corporate Criminal “Investigations” (Part I of IV)

The Justice Department continues to be dogged by questions surrounding its conduct of criminal investigations. These concerns are being raised in the context of extreme cynicism given DOJ’s “failure” to prosecute individuals…more
| Administrative Law, Commercial Law & Contracts, International Law & Trade, Securities Law

FinCEN Flexes Its Muscles

The Treasury Department’s Financial Crimes Enforcement Network has been flexing its muscles lately to remind everyone of its important role in money laundering enforcement. Jennifer Shasky, the current Director, a former…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Real Estate - Commercial

Risk Assessment: A Natural Partnership for Internal Auditors and CCOs

In the corporate compliance world, chief compliance officers and internal auditors are natural allies. They often report to the same board committee, share a common perspective on corporate operations, and are aimed at…more
| Commercial Law & Contracts

Front Lines of Compliance: First Line of Defense

Chief Compliance Officers carry a lot of weight on their shoulders. Some days, I am sure, they have trouble getting up and soldiering on to tackle the next challenge…more
| Commercial Law & Contracts

Third Party Risk Management

There is something in a name. More people in the compliance industry, when referring to third-party due diligence, are labeling it “Third Party Risk Management.” I like it because it is more accurate…more
| Commercial Law & Contracts

If Only the New England Patriots Had a CCO: Lessons from “Deflategate”

If only the New England Patriots had an Anti-Bribery and Anti-Corruption program, “Deflategate” might never have entered America’s vocabulary. The long-running saga re-entered the media this past week with the release of the…more
| Art, Entertainment, & Sports Law, Commercial Law & Contracts

Automation and AML/BSA Compliance

The future of compliance includes technology solutions. Do not get me wrong – technology is not a panacea but it is an important strategy for leveraging resources. In the anti-corruption and sanctions compliance arenas,…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Science, Computers, & Technology

Happy Talk and CCO Reporting to the Board

Everyone likes to talk. For most people, it is hard to listen. Chief Compliance Officers have to be proficient at both, especially listening. I have often criticized CCOs who engage in Happy Talk when reporting their boards. It…more
| Commercial Law & Contracts
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Washington, D.C. , United States

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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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