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 [email protected].
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.
What a difference a year makes — The Treasury Department’s Office of Foreign Asset Control (OFAC) announced two sanctions settlements in the beginning of 2019, a stark difference from 2018 when OFAC announced its first enforcement action in June 2018. Michael Volkov provides specifics on sanctions violations from Kollmorgen and the cosmetics company ELF. ELF Cosmetics On January 31, 2019, OFAC announced...
Read more
When companies are in financial straits, budget cuts are a reasonable expectation. But how deep should the cuts go when it comes to the E&C program? Businesses can’t profess their support for ethics and compliance and then strip resources away. A fundamental requirement for an effective ethics and compliance program is that it is supported by "adequate resources." This does not mean a...
Read more
Findings from NAVEX’s Annual Study NAVEX Global recently released the annual Hotline and Incident Management Report, a key tool compliance practitioners can use to benchmark and evaluate the performance of the company’s reporting hotline. Michael Volkov provides an overview of the findings, discussing trends and assumptions. Employee hotlines are – sorry about this – a "hot" topic these days in compliance. NAVEX...
Read more
The More Things Change, The More They Stay the Same With 2018 officially behind us, Michael Volkov looks at FCPA enforcement in 2018, discussing some of the DOJ’s most notable actions. Happy New Year! Another year is in the books for FCPA enforcement and compliance. The headline for this past year (like many other years) is/was – The more things change, the more...
Read more
And Striking the Right Balance to Fight It The reality is that the vast majority of corporations have a fraud problem to some degree. It’s a growing problem – one indicator pointing to a rise in overall economic crime globally. Michael Volkov outlines various methods to detect and prevent fraud and gives us a peek into the mind of a corporate fraudster....
Read more
To Prevent and Detect Compliance programs exist for the purpose of protecting against misdeeds, and the most effective programs are those that exist within a culture of ethics. Michael Volkov discusses the truism that a company’s culture and its compliance controls are mutually reinforcing. I do not think there is much disagreement on the basic purpose of an ethics and compliance program....
Read more
Why Your E&C Program Should Be Operationalized An ethics and compliance program is in trouble from the start if it meets with staunch opposition from any element within in the organization. Michael Volkov explains why the best programs are operationalized, with buy-in and cooperation from every function. The beauty of an effective ethics and compliance program is captured in the well-known phrase...
Read more
Indictments and Other Developments Following indictments unsealed last week, Michael Volkov revisits the 1MDB scandal, from the major players to the various wrongdoings. The 1Malaysia Development Berhad scandal (1MDB scandal) has been making headlines for the past few years. The turning point for U.S. prosecutors was the cooperation of Malaysian law enforcement and the corruption allegations surrounding Malaysia’s former Prime Minister Najib Razak. At...
Read more
A Call for Greater Multidisciplinary Oversight As your company’s reliance on third parties grows, so too does the risk associated with doing business with these relatively unknown partners. Michael Volkov entreats companies to put in place more robust due diligence processes to minimize their third-party risks. Believe it or not, but companies are still struggling with third-party risk management systems. I know...
Read more
Resulting Settlements and Remedial Measures Brazilian oil and gas giant Petrobras has entered into a series of settlements in closing out corruption investigations and litigation. For a long period of time, corruption was endemic at the corporation (the DOJ estimates illegally generated funds for payments as at least $2 billion), and the bill is finally coming due. When it comes to a...
Read more
What the Decision on Epsilon's Sanctions Violations Means for Companies Michael Volkov discusses Epsilon's sanctions violations, the resulting "reason to know" requirement and the potential impact to companies going forward. The Department of Treasury’s Office of Foreign Asset Control (OFAC) recently announced the settlement of the Epsilon enforcement action (here). This case requires a theme song and there is none better than Truckin (here)...
Read more
Conspiracy Count Dismissed in Ruling on United States v. Hoskins In a recent case heard by the U.S. Court of Appeals, Lawrence Hoskins, a former executive at Alstom, was charged with conspiracy to bribe foreign officials. The Court’s decision in the case calls into question just how long the DOJ’s reach really is with respect to the FCPA. The Justice Department’s attempt...
Read more
CCI is the Web's premier independent news source for compliance, ethics, audit & risk. CCI is owned and managed by CCI Media Group LLC.
