Michael Volkov – The Volkov Law Group

Parallel Universes: Antitrust Leniency and the FCPA Pilot Program

The world of science fiction can be exhilarating. If you ever read The Foundation Trilogy or Martian Chronicles, you know what I mean. The concept of parallel universes has always been an intriguing idea where believers can…more
| Antitrust & Trade Regulation, Commercial Law & Contracts, Consumer Protection, International Law & Trade

The FCPA Pilot Program Disciplinary Standards (Part II of II)

Returning to the FCPA Pilot Project requirements for timely and appropriate remediation, the Justice Department added three new elements, one of which reinforces the CCO “independence” requirement. The two other elements for an…more
| Commercial Law & Contracts, International Law & Trade

Unpacking the Justice Department’s Compliance Remediation Standards (Part I of II)

The Justice Department has a lot to be proud about when it comes to its FCPA enforcement program. In one area in particular – promoting effective ethics and compliance strategies – DOJ’s FCPA prosecutors have played a leadership…more
| Commercial Law & Contracts, International Law & Trade

Yikes: The Perils of Remediation and Corporate Monitors

The Justice Department has raised the stakes on anti-corruption compliance. In other words, DOJ prosecutors expect companies to have more sophisticated and mature compliance programs. If a company walks into the Justice…more
| Commercial Law & Contracts, International Law & Trade

Focus on the Issue of “Corrupt Intent”

Legal and compliance practitioners are often asked to review a set of facts and determine whether the actors will potentially violate the FCPA. A lot has been written on the vagueness or lack of clarity surrounding the FCPA…more
| Commercial Law & Contracts, International Law & Trade

The Test for Bad Actors in a Bad Company

Some business people are “bad,” meaning they engage in misconduct and either feel no remorse or rationalize why their conduct is acceptable. In a company that embraces bad acting, breaking rules or cutting corners, bad actors…more
| Commercial Law & Contracts

The Challenges Facing the Antitrust Leniency Program and the Yates Memorandum

The Justice Department’s Antitrust Division has a long history of independence within the US Department of Justice. Antitrust enforcement was considered a unique area requiring a specialized understanding of markets and…more
| Antitrust & Trade Regulation, Commercial Law & Contracts, Consumer Protection

SEC Snares Two “Masterminds” Behind Och-Ziff Bribery Scheme

The SEC recently filed a lengthy civil complaint against two Och-Ziff executives: Michael Cohen, who headed Och-Ziff’s European office, and Vanja Barros, an executive responsible for Africa-related transactions, charging them…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Walking the Walk and Talking the Talk – A CEO’s Commitment to Ethics and Compliance

The phrase tone at the top is becoming trite. Compliance professionals use it over and over, and few people explain how to apply the concept. Speakers and webinar presenters always gloss over tone at the top, emphasizing its…more
| Commercial Law & Contracts

The Win-Win Argument: Compliance as a Marketing Advantage

My good friend and colleague Dan Chapman, now the CCO at VimpelCom, is a compliance rock star. I have known Dan for years, beginning when he took over at Parker Drilling and implemented a world-class remediation program to pull…more
| Commercial Law & Contracts, International Law & Trade

Las Vegas Sands Suffers Double Whammy and Resolves FCPA Action with DOJ for $7 Million

Following a separate SEC action, the Justice Department resolved FCPA charges against Las Vegas Sands for $7 million. DOJ and Las Vegas Sands entered into a non-prosecution agreement (NPA) citing much of the same evidence…more
| Commercial Law & Contracts, International Law & Trade

Serious Fraud Office Makes Big Splash with UK Bribery Act Resolution with Rolls Royce

After years of fits and starts, and promises and disappointments, the Serious Fraud Office and the UK Bribery Act made its initial splash on the anti-corruption enforcement landscape. Since 2011, companies have been warned…more
| Commercial Law & Contracts, Energy & Utilities, International Law & Trade

C-Suite Misconduct Results in Sociedad Quimica Y Minera FCPA Resolution with DOJ and SEC

In an unusual FCPA enforcement action, the Justice Department and the SEC resolved FCPA violations against Sociedad Quimica y Minera, a Chilean chemical and mining company, for a total of $30.5 million, for paying approximately…more
| Commercial Law & Contracts, International Law & Trade

FCPA Recidivists: Orthofix (Part II of II)

In its continuing quest to push the message of aggressive FCPA enforcement, the SEC resolved FCPA charges against Orthofix, a medical device company, for $6 million in penalties and disgorgement. In a related action, the SEC…more
| Commercial Law & Contracts, International Law & Trade

FCPA Recidivists: Zimmer Biomet (Part I of II)

The drug and medical device industries have been taking it on the FCPA chin for years. The risk factors in the international marketplace are significant – healthcare professionals are normally government employees; government…more
| Commercial Law & Contracts, International Law & Trade, Science, Computers, & Technology
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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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