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I am excited to announce the addition of three new members of The Volkov Law Group. When I launched the firm, I was committed to providing high-quality ethics and compliance, and enforcement defense services. With the help of my existing members, Lauren Connell, Dave Lusby, Evan Lee and Jon
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The FCPA Guidance turned two years old recently – November 14 to be exact. No one wrote about the milestone, nor has anyone praised the FCPA Guidance. To be the contrarian, I am writing to wish the FCPA Guidance a very happy birthday and to sing its praises. In honor of
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It is important to acknowledge and respect your roots. It is great to welcome new and important legal bloggers. Starting out a blog for professionals is a challenging and fun process. Two new entrants on the blogosphere are worthy of everyone's attention. Sidebars: Randall Eliason has started a
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I am pleased to announce that The Volkov Law Group’s recorded webinars can now be downloaded from ITunes. As many of you know, The Volkov Law Group maintains a You Tube Channel that includes recordings of all the webinars we have conducted over the past two years. The You
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Companies and Chief Compliance Officers have taken significant actions to emphasize the importance of a company’s code of conduct. A well-designed code of conduct is a foundation for an effective ethics and compliance program. It is the core from which other policies and procedures are designed. It presents
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In the FCPA world, we tend to get myopic. We see complex issues and business operations through the prism of anti-corruption risks. Businesses and Chief Compliance Officers, however, have a very different perspective. When pontificating on life lessons to my children (who are no longer children), I frequently cite
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The Fourth Quarter of 2014 has been a busy one for DOJ and SEC in the FCPA arena. We are all praying that DOJ and SEC resolve the Avon case soon so that we do not have to include the case on our lists for predictions for 2015 FCPA enforcement
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The FCPA enforcement doomsayers can add another notch to their belt – their predictions and suggestions of “enforcement slow downs,” “significant policy changes,” and other misguided claims can be added to the ash heap of erroneous predictions. It is amazing how supposed “analysis” is produced to fill the gaps in time
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With the rise of the compliance professional, there is a real need for strong support as they design and implement new and innovative compliance programs. Compliance professionals are stretched thin – they have a mountain of responsibilities but only an anthill of resources to commit to the job. They are constantly
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The Antitrust Division is a world unto itself. Ask anyone who works there (including me) or worked there and they will tell you that everyone refers to the Antitrust Division as “The Division,” like it is the only Division in the Department of Justice. That attitude, however, occasionally carries into
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For years (okay 3 years), I have written about the need for DOJ to address its policies surrounding voluntary disclosure. DOJ and the SEC regularly urge companies and FCPA practitioners to disclose FCPA violations to DOJ in order to earn a possible declination, deferred prosecution agreement, or a reduced penalty.
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The 2014 mid-term elections were over in a snap. Now everyone is focused on the Presidential contest for 2016. After all, the Iowa causes are not very far away. In the last thirty years, DOJ’s agenda has become more political with each new Administration. For example, the Antitrust