Michael Volkov

Michael-Volkov-leclairryan

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.

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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orange post-it with happy face surrounded by gray post-its with sad faces

“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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top view of team with hands stacked in half huddle

Compliance professionals’ jobs are made immeasurably more difficult without the support of the board. Michael Volkov offers five concrete actions the compliance department can take to enhance the board-compliance relationship. In today’s aggressive enforcement environment, corporate board members have a target on their respective backs. Even with robust liability insurance, corporate boards are operating in a state of “ignorance is bliss.” Chief compliance...

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businessman facing wall with arrows pointing left and right

Michael Volkov posits a reasonable definition of business ethics – and outlines what it’s NOT – and offers a framework for going beyond determining whether a decision is “legal” and instead determining whether it is “right.” Forgive me for the title of this posting. I am trying to make a point; a rather obvious one. I confess: I did not take philosophy classes...

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barclays sign on stone building

Michael Volkov details the recent FCPA settlement against Barclays for improper hiring practices stretching back several years. One key factor that allowed the issue to continue for so long: a seeming lack of awareness of applicable anti-corruption laws. Barclays joined the club of global financial institutions settling FCPA violations for hiring of relatives of foreign officials in Asia. Barclays agreed to disgorge $3.8...

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red employee icon showing impact on other connected staff, concept of corruption and nepotism

Deutsche Bank’s hiring practices in the Asia-Pacific region have exposed the institution to corruption risk, and SEC has taken note. Michael Volkov provides details on the company’s recent FCPA settlement with the SEC. If there ever was a poster child for reputational damage for a financial institution, Deutsche Bank would be the first and only candidate. Talk about a bank that is in...

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glasses on table putting forest into focus

Michael Volkov explores what may be an unpopular opinion among some in the compliance community: In terms of risk management priorities, data security may be getting far too much attention. This is likely to be a politically incorrect posting. I hope I do not offend too many people, especially those new data privacy professionals. As kids, we were always excited when an ice...

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