Author: Michael Volkov

UK Bribery Act Guidance: No Guidance At All

UK Bribery Act Guidance: No Guidance At All

If you don’t know where you are going, you might wind up someplace else. — Yogi Berra After all the dust has settled, the political recriminations have been leveled, and the issuance of reams of client alerts by every law firm on the planet, companies are now staring at July 1, 2011, the effective date of the UK Bribery Act. The build up to the...

UK Bribery Act Guidance: No Guidance At All

UK Bribery Act Guidance: No Guidance At All

If you don’t know where you are going, you might wind up someplace else. — Yogi Berra After all the dust has settled, the political recriminations have been leveled, and the issuance of reams of client alerts by every law firm on the planet, companies are now staring at July 1, 2011, the effective date of the UK Bribery Act. The build up to the...

World Compliance FCPA Tour — April 20 in Palo Alto

World Compliance FCPA Tour — April 20 in Palo Alto

The FCPA Tour takes to the road again.  Join us on April 20 in Palo Alto.  Dick Cassin from the FCPA Blog, Ryan Morgan from World Compliance and myself will be there.  Registration is free. Here is the link FCPA compliance for the tech world has taken on new significance given recent reports of ongoing investigations of tech companies focusing on operations in Asia, as reported...

Welcome to Day 1

Welcome to Day 1

I wanted to welcome everyone to my white collar defense and compliance blog.  Welcome to Day 1 of my new blog. I am happy to join the blogging community.  I hope I can provide readers with valuable insights and counsel on white collar defense and complaince issues.  I started the blog in response to increasing demand for timely information and to provied convenience for readers. I...

Reading The Tea Leaves: DOJ’s Recent FCPA Enforcement Actions

Reading The Tea Leaves: DOJ’s Recent FCPA Enforcement Actions

Earlier this year, at a Houston FCPA Conference, the Justice Department and the SEC predicted that their aggressive enforcement policies would continue.  So far this year, they have been right on the mark.  Even with additional litigation responsibilities in the Shot Show case and three pending criminal cases set for trial this spring and summer, DOJ’s recent  FCPA settlements continue at a record pace and...

Justice Department Provides More Guidance on FCPA Compliance

Justice Department Provides More Guidance on FCPA Compliance

            On April 8, 2011, Johnson & Johnson settled criminal FCPA allegations and agreed to “pay a $21.4 million penalty to resolve criminal FCPA charges with the DOJ and $48.6 million in disgorgement and prejudgment interest to settle the SEC’s civil charges.”               As part of the settlement, Johnson & Johnson agreed to a Deferred Prosecution Agreement (DPA) which included two important attachments outlining compliance...

Justice Department Provides More Guidance on FCPA Compliance

Justice Department Provides More Guidance on FCPA Compliance

            On April 8, 2011, Johnson & Johnson settled criminal FCPA allegations and agreed to “pay a $21.4 million penalty to resolve criminal FCPA charges with the DOJ and $48.6 million in disgorgement and prejudgment interest to settle the SEC’s civil charges.”               As part of the settlement, Johnson & Johnson agreed to a Deferred Prosecution Agreement (DPA) which included two important attachments outlining compliance...

The Person of the Year — The Chief Compliance Officer

The Person of the Year — The Chief Compliance Officer

Since we are closing in on the end of 2011, it is time to join the crowd and select the person of the year award — even in our narrow field of reference: compliance.  For me there is no question — it is the chief compliance officer.  There is no other position in a company which has taken on more significance. All you need to do is consider...