Author: Michael Volkov

Webinar: A Deep Dive into the Russia-Ukraine Sanctions Program

Webinar: A Deep Dive into the Russia-Ukraine Sanctions Program June 12, 2018 12 Noon EST Sign Up Here Sanctions compliance has become more complex and difficult. The Russia-Ukraine Sanctions Program includes detailed sectoral sanctions and comprehensive “oligarch” sanctions against Russia’s leading industrial oligarchs. Compliance officers have to ensure that their trade compliance programs are nimble and able to adapt to the ever-changing compliance environment. Join...

Compliance and the Reckoning

The compliance profession cannot rest on its achievements and become complacent.  There are two significant events that are on the horizon and inevitably will occur. Compliance professionals have grown in number and in influence.  At the same time, compliance professionals are enjoying unprecedented independence and authority.  As the compliance profession rises, however, so will accountability – fair or unfair, it is soon about to hit....

The Vital Role of Internal Audit to Compliance

A chief compliance officer can only succeed with the support of other important compliance partners.  Another way to put it – in the words of Blanche Dubois from A Streetcar Named Desire, “I have always depended on the kindness of strangers.”  This observation, while dramatic in license, applies to the place of the compliance officer in the corporate governance world. A key partner for compliance...

Episode 40 — How to Conduct a Corporate Culture Assessment

Research has consistently demonstrated that an ethical corporate culture results in increased profits and sustainable growth.  Companies with a positive culture have lower rates of employee misconduct, increased employee productivity, and lower employee turnover.  All of these factors lead to higher growth rates, improved employee morale, and a reduced risk of misconduct and government investigation. This basic premise holds true: when ethical values are embedded in a company’s...

Sunshine, Disinfectant and SEC Guidance on Cybersecurity Disclosures

The fundamental principle of SEC’s market regulation is the power of sunshine, transparency and disclosure.  In other words, the SEC seeks to ensure that companies disclose important information to the public so that securities markets operate efficiently.  Whether the SEC has appropriately applied this principle in regulating the securities industry is a debate for another day.  The SEC, however, has used this policy goal to...

CEOs Under the Criminal Spotlight – More C-Suite Misconduct

We live in a bizarre time — an information age where lines are blurred between truth and lies — a strange era in which our daily doses of information are dominated by scandals, corruption, and repeated claims of “fake news.”  One of the unfortunate consequences is that otherwise important issues often fade in competition with these ever-pervasive scandals.  Please do not misunderstand me – the...

Tom Fox’s Valuable Contribution to the Compliance Profession – The Complete Compliance Handbook

Tom Fox has been called the “Compliance Evangelist.”  Whatever title may be given to Tom, one thing is for sure – Tom is a steady force, providing practical advice to advance the compliance function. To that end, Tom’s latest contribution is a new tome – The Complete Compliance Handbook: A Guide to Operationalizing Your Compliance Program.  I recently received my autographed copy of Tom’s new...

Volkov Law — In the News and on the Web

Michael Volkov Quoted by ABC News:  Michael Avenatti casts himself as anti-Trump avenger, May 16, 2018 HERE The inspector general of the Treasury Department is now investigating possible leaks of Suspicious Activity Reports, or SARs, from Cohen’s financial institutions. “Suspicious activity reports are confidential. They’re not allowed to be leaked,” said Michael Volkov, a white-collar defense lawyer who spent seventeen years as a federal prosecutor...

Episode 39 — Tom Fox’s New Book — The Complete Compliance Handbook

Tom Fox is a thought leader for the ethics and compliance profession.  He is a prolific writer who has produced a steady body of work — podcasts, books, blogs, articles — to advance the compliance function.  He is knowledgeable, practical and insightful on how to implement and maintain an effective compliance program. Tom has just released a new and important book — The Complete Compliance Handbook. ...

Time for Companies to Establish an Independent Corporate Ombudsman

Corporate commitment to speak up cultures is suffering.  The Ethics and Compliance Initiative’s recent Global National Business Ethics Survey (available HERE) contained a critical finding – corporate instances of retaliation against employee for raising concerns doubled in the last five years. In the 2013 survey, 22 percent of respondents reported instances of retaliation against employees.  This number increased to an astounding 44 percent of respondents...