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.
If your business activities take place in the U.S., you need to be doing OFAC screening. Michael Volkov offers five areas most companies that most organizations fitting this description could stand to improve upon to ensure compliance. As companies elevate their “game” in sanctions compliance, it is important that compliance officers critically examine the strengths and weaknesses of their compliance programs. Many companies...
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A CCO’s most valuable resource is time. But with high expectations and limited resources to do the job well, CCOs can quickly become overwhelmed. Michael Volkov provides a framework for dealing with some of the role’s greatest challenges. Chief compliance officers have a hard job. CCOs know that fact, and they fully embrace the challenges of their positions. At the same time, CCOs...
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Michael Volkov highlights three sanctions-related enforcement actions all breaking in the last six weeks – and two of which involved travel services to Cuba. He covers the violations, the circumstances and the penalties. OFAC is clearly sending a message about sanctions enforcement and compliance responsibilities. The agency is aggressively seeking out new targets for enforcement and continues to focus on Iran, Cuba, Venezuela...
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Findings from recent studies on compliance trends and developments are a mixed bag; some positive, some negative. Michael Volkov shares an uncharacteristic view of corporations and their failures to embrace E&C strategies. We all like to believe in straightforward and consistent trends and developments. For example, compliance programs are improving, budgets are increasing and CCOs are embracing new technologies. Everything is just rosy when...
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GRC professionals in particular know the importance of tone at the top. When a leader has an ethical lapse, the ramifications can be far-reaching. Michael Volkov discusses the potential fallout of managerial misdeeds. Company managers are the linchpin of a corporate compliance program. Without belaboring the “Tinker to Evers to Chance” baseball analogy, a corporate culture of compliance requires an important information and...
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Michael Volkov details the settlement between the U.S. OFAC and Haverly Systems, which was found to be in violation of federal sanctions.
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Michael Volkov sheds light on recent False Claims Act cases brought against Duke University and MedStar Health – both with violations spanning multiple years.
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The Department of Justice has recently amended its policy on corporate enforcement of the Foreign Corrupt Practices Act. Michael Volkov covers the DOJ’s clarification of the de-confliction parameters, as well as its stance on the use of ephemeral messaging systems like WhatsApp.
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News broke last week of a scandal in which high-profile executives and celebrities allegedly used bribery to secure their children’s admission to colleges across the U.S. Michael Volkov gives background on the story and its principal players. In a shocking announcement, federal prosecutors announced the arrest and charges against numerous individuals in connection with a nationwide criminal investigation focusing on college entrance...
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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...
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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...
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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...
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