General
Happy Thanksgiving!
Happy Thanksgiving to our clients, friends, colleagues, and family!! We hope you have a wonderful and restful holiday. With peace and gratitude, The Volkov Law Group PC
Latest
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The Continuing Importance of Conflict of Interest Compliance
We continue to hear about the impact of apparent or real conflicts of interest -- whether in government, in business, or in other organizations. It is an issue of significant importance. Within an organization, a perceived or real conflict of interest can undermine the very integrity of the organization and a
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Measuring Compliance Program Performance and Effectiveness
"Only when the tide goes out do you discover who's been swimming naked." — Warren Buffett You often hear chief compliance officers speak about benchmarking. CCOs often reveal their competitive streaks when they collect information about other companies' compliance programs. It can easily come off as
Podcasts
Episode 346: Forecasting the 2nd Trump Administration Enforcement and Compliance Impact
As the dust settles on the U.S. Election, companies are quickly analyzing the implications for the economy, business environment, new enforcement priorities and compliance implications. When new Administrations come into power, change is inevitable. Given the change with President Trump's return to the White House, and in
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Lessons Learned from the Telefónica FCPA Settlement (Part III of III)
The Justice Department's record of FCPA enforcement in 2024 has been disappointing. With all of the hoopla and pronouncements surrounding the global war against corruption, DOJ suggested that enforcement in 2023 and 2024 would be robust. Instead, 2024 was a year of fizzles, fits and starts, and ultimately
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Telefónica's Bribery Scheme -- The Usual Suspects and Tools (Part II of III)
We should all admit something (among many things) -- reading through factual statements of bribery offenses, the facts all start to meld together. Criminals are not as ingenuous or creative as they think, and the schemes they employ are fairly straightforward. Let's start with one profound grasp of the
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Telefónica Pays $85.2 Million to Settle FCPA Charges involving Venezuela Bribery (Part I of III)
Telefónica Venezolana C.A. ("Telefónica Venezolana"), the Venezuela-based subsidiary of Telefónica S.A. (Telefónica), the Spanish telecommunications company entered into a deferred prosecution agreement ("DPA") and agreed to pay over $85.2 million to resolve DOJ FCPA charges stemming from bribery payments to Venezuelan government
Events
Webinar: DOJ's Recent Compliance Program Guidance
Webinar: DOJ's Recent Compliance Program Guidance December 3, 2024, 12 Noon EST Sign Up HERE In September and November 2024, the Department of Justice issued revised versions of its Evaluation of Corporate Compliance Program ("ECCP") and its Evaluation of Corporate Compliance Programs in Antitrust Criminal Investigations
Podcasts
Episode 345 -- Raytheon Settles for $950 Million for Fraud, FCPA, ITAR and False Claims Act Violations
Raytheon Company (Raytheon) -- a subsidiary of defense contractor, RTX (formerly known as Raytheon Technologies Corporation) — agreed to pay over $950 million to resolve the Justice Department’s investigations into: (i) a major government fraud scheme involving defective pricing on certain government contracts; (ii) violations of the Foreign Corrupt Practices Act
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The Trump Administration's Focus on the Department of Justice and Priorities (Part III of III)
The Justice Department is about to undergo some fundamental changes. The 2nd Trump Administration will take some initial broad strokes designed to increase accountability and control of prosecutors and laws enforcement. The FBI The first on the chopping block is the FBI. Under existing law, the FBI is a component
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Forecasting the 2nd Trump Administration: Foreign Policy Changes and Increased Trade and Tariff Enforcement (Part II of III)
The 2nd Trump Administration will mean significant change in foreign policy, most especially the importance of ending the Russia-Ukraine war, increased focus on Iran and its proxies, and aggressive use of trade policies and tools to execute the policy and promote United States businesses. Since the start of the
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Forecasting the 2nd Trump Administration: Translating Initiatives to Enforcement and Compliance Priorities (Part I of III)
As the dust settles on the U.S. Election, companies are quickly analyzing the impact for businesses, federal civil and criminal enforcement priorities and the implications for ethics and compliance. When a new Administration comes into power, change is inevitable and can be far-reaching. Given the change with President