Michael Volkov
The Volkov Law Group

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Washington, D.C., United States
Phone: (240) 505-1992
Areas of Practice
  • Antitrust & Trade Regulation
  • Criminal Law
  • Energy & Utilities
  • Finance & Banking
  • Government
  • International Law & Trade
  • Litigation
  • Mergers & Acquisitions
  • Securities Law

May 2018: D-Day for FinCEN Customer Due Diligence and EU’s General Data Privacy Regulations

Chief compliance officers for financial institutions are going to have a rough May 2018. First, on May 11, 2018, the new CDD Rule for beneficial ownership becomes effective. Two weeks later, on May 25, 2018, the EU’s General…more
 /  Commercial Law & Contracts, International Law & Trade

Calculating the New Balance Between Disclosure and Non-Disclosure of Potential FCPA Violations

The Justice Department’s new FCPA Corporate Enforcement Policy has altered the balance between disclosure and non-disclosure of FCPA violations. How is that for a profound grasp of the obvious?…more
 /  Commercial Law & Contracts, International Law & Trade

Pushing Ethics and Compliance Programs in the New FCPA Corporate Enforcement Policy

The Justice Department’s aggressive enforcement program, particularly in the FCPA arena, has been the primary impetus to the growth and empowerment of the corporate compliance function. The Justice Department and SEC’s FCPA…more
 /  Commercial Law & Contracts, International Law & Trade

Practical Ethics – The New Way to Advance an Ethical Culture

I have always been struck by the “feel good” advocacy and advice from so-called ethics “experts.” Sure, it is great to talk about moral values, ethical principles, and other high-minded ideas that inspire an audience to embrace…more
 /  Commercial Law & Contracts, International Law & Trade

Sanctions Updates: Cuba, North Korea, Russia, Sudan, Venezuela

Sanctions compliance is challenging because of the changing nature of sanctions regulations and individuals identified as Specially Designated Nationals. With each new administration, foreign policy priorities are usually played…more
 /  Business Organizations, Commercial Law & Contracts, Finance & Banking, International Law & Trade

Foreign Agents Registration Act Enforcement

One consequence of the ongoing Russia investigation against the current administration is increased focus and probable enforcement of the Foreign Agents Registration Act (FARA). For Washington insiders, FARA was a known…more
 /  Commercial Law & Contracts, Elections & Politics, International Law & Trade

SBM Offshore Finally Reaches the Finish Line and Settles FCPA Case for $238 Million

In a follow-on prosecution and end to a twisted investigation and enforcement path, SBM Offshore agreed to settle an FCPA enforcement matter for $238 million (including a $500,000 criminal fine and $13.2 million forfeiture)…more
 /  Commercial Law & Contracts, International Law & Trade

Five Key Takeaways from DOJ’s New FCPA Corporate Enforcement Policy

In a significant FCPA enforcement development, DOJ’s Deputy Attorney General (“DAG”) Rod Rosenstein last announced the implementation of a new FCPA Corporate Enforcement Policy. The announcement was not a surprise based on…more
 /  Commercial Law & Contracts, International Law & Trade

Episode 13 -- Top Ten Rules for Conducting Internal Investigation Interviews [Audio]

To implement an effective ethics and compliance program, global companies have to establish an effective internal investigation program.  Whether conducting a critical or routine investigation, investigators have to be able to…more
 /  Criminal Law, Government Contracting, International Law & Trade, Science, Computers, & Technology, Securities Law

Incorporating AML Compliance Into a Compliance Program (Part III of III)

Global companies should implement an AML program and KYC practices that follow the general outline for best practices, though it does not need to be as rigorous as a financial institution. For most companies, AML risks can be…more
 /  Commercial Law & Contracts, International Law & Trade

Addressing AML Risks in Your Third-Party and Vendor/Supplier Relationships (Part II of III)

Global companies should incorporate AML risks into their risk analysis of their third-party distributors, agents and other intermediaries. The basic questionnaire, due diligence risk analysis, contractual provisions, training,…more
 /  Commercial Law & Contracts, International Law & Trade

Anti-Money Laundering Risks for Global Companies (Part I of III)

Non-financial institution companies operating in the global marketplace face ever-increasing risks of money laundering. Sophisticated criminal organizations have developed their own mechanisms and strategies to skirt money…more
 /  Commercial Law & Contracts, International Law & Trade

DOJ Continues Run on Individual FCPA Criminal Prosecutions

The Department of Justice announced criminal FCPA charges against two individuals in connection with bribery payments to foreign officials in Chad and Uganda. The Justice Department’s announcement occurred on the heels of…more
 /  Commercial Law & Contracts, International Law & Trade

Third Party Risk Management: Require ISO 37001 Certification from Your Third Parties

A lot of the focus on ISO 37001 so far has been on its value for companies considering certification as evidence of the quality of their own compliance program. With the SEC and DOJ both providing ample guidance to companies in…more
 /  Commercial Law & Contracts, International Law & Trade

Internal Investigations: Protecting the Attorney- Client Privilege

I like to repeat myself – attorneys are valuable for only two reasons: (1) attorney-client privilege; and (2) advice of counsel defense. I know I am not supposed to denigrate my profession but these are two important reasons,…more
 /  Commercial Law & Contracts, International Law & Trade
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