Michael Volkov


Michael Volkov is the CEO of The Volkov Law Group LLC, where he provides compliance, internal investigation and white collar defense services.  He can be reached at mvolkov@volkovlaw.com.

Michael has extensive experience representing clients on matters involving the Foreign Corrupt Practices Act, the UK Bribery Act, money laundering, Office of Foreign Asset Control (OFAC), export controls, sanctions and International Traffic in Arms, False Claims Act, Congressional investigations, online gambling and regulatory enforcement issues. Michael served for more than 17 years as a federal prosecutor in the U.S. Attorney’s Office in the District of Columbia; for five years as the Chief Crime and Terrorism Counsel for the Senate Judiciary Committee, and Chief Crime, Terrorism and Homeland Security Counsel for the Senate and House Judiciary Committees; and as a Trial Attorney in the Antitrust Division of the U.S. Department of Justice.

Michael also maintains a well-known blog: Corruption Crime & Compliance, which is frequently cited by anti-corruption professionals and professionals in the compliance industry.

Illustration of a handshake

In-house counsel and compliance both assess risk. As such, they often vie with one another. A collaboration, however, can serve to raise both up and significantly enhance a company's risk assessment overall. Lawyers get a bad rap – not just as the subject of lawyer jokes.  (This is not an invitation to recite lawyer jokes).  I recently wrote about the unique skills...

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CCO listening to risk management

Chief Compliance Officers can add value to their organizations in many ways -- but are they at liberty to do so? Michael Volkov suggests it's time to give these multi-talented professionals more room to roam. Chief compliance officers are talented professionals. As Donna Boehme always emphasizes, CCOs are subject matter experts in compliance risks, controls and mitigation. They focus on legal and...

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OFAC has brought two enforcement actions against digital currency services providers in as many months – the latest, against BitPay, should spur companies to develop risk-based sanctions compliance programs. Michael Volkov discusses the violations. The Treasury Department’s Office of Foreign Asset Control continues to focus enforcement activities on digital currency companies. This focus is likely to increase given recent comments by Janet Yellen,...

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green plant growing on glass jar with coins

Finance experts are increasingly aware of environmental, social, and governance (ESG) issues. This trend did not come out of nowhere; it's a response to investor demand. Michael Volkov explores the growth of ESG and the actions companies can take now. Corporate governance sometimes is the subject of “fads,” or initiatives that gain traction with dubious evidence-based justifications. Sometimes companies engage new theories...

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AAG Brian Benczkowski’s 2018 memo on selecting corporate monitors states that one should only be imposed when there’s a “clear benefit” of doing so. And yet there was none imposed on the Goldman Sachs case. Michael Volkov discusses. In 2020, the Justice Department did not insist on the appointment of any independent compliance monitors. The year before, in 2019, the DOJ insisted on...

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wrench with 100 dollar bills

We've heard the warnings about criminal indictments against companies engaging in no-poach or wage-fixing agreements. Now the DOJ's Antitrust Division puts its money where its mouth is.  Michael Volkov provides details on the criminal cases against Surgical Care Affiliates and Neeraj Jindal. The DOJ’s Antitrust Division has warned that it would bring criminal indictments against companies that enter into illegal no-poach or wage-fixing agreements. The...

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transition from grayscale to diversity

California’s recently signed Assembly Bill 979 is requiring organizations to diversify their boards of directors. As Michael Volkov writes, the change is not only long overdue, but also in organizations’ best interests. The United States continues to lag in corporate board diversity; many corporate boards are dominated by white males. Progress on this issue has been slow. The number of women on Russell...

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cardboard boxes and airplane lifting off with prohibited symbol on gray background

With OFAC’s reach lengthening in the past few years, organizations should play close attention to their sanctions compliance program (SCP). Michael Volkov outlines five key actions to take now to ensure an effective SCP. Companies have to implement a sanctions compliance program (SCP). When I use the term SCP, I mean much more than just having one employee screen a customer before...

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“Happy talk” amounts to empty words absent a frank, honest discussion of the issues. Michael Volkov explains one reason why so few compliance programs measure up. Chief compliance officers are heroes. They labor every day to advance a company’s ethics and compliance program without much recognition, with few resources and with well-known gaps in their programs. CCOs live by a credo – they...

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red paper airplane changing course from line of white paper airplanes

Changing trends, risks and demands necessitate changes in response. Michael Volkov asserts that boards must shift to a broader approach, replacing a single-minded focus on profits with measured consideration of the interests of a wide range of stakeholders. Corporate boards are under increasing attack by investors, shareholders and the public. In the aftermath of corporate legal train wrecks – such as Wells...

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finger over green report button on white keyboard

The DOJ recently announced updates to its FCPA Corporate Enforcement Policy. Michael Volkov shares how, while the changes were relatively minor, the modifications underscored important principles surrounding the FCPA Corporate Enforcement Policy. There is no question that the DOJ has landed on a Corporate Enforcement Policy that took years to develop. The FCPA Corporate Enforcement Policy now applies to all corporate criminal prosecutions...

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