Category: General

Complaints to Investigations to a Speak Up Culture: Maintaining Important Connections

Like Tinkers to Evers to Chance completing a double play, compliance programs need to maintain important links among three key elements – its complaint system, the handling of such complaints, and the publicized resolution of such complaints to encourage its Speak Up culture. Complaint Reporting Channels: Many companies have more than one avenue for officers, managers and employees to complain. That is a good thing....

The Intractable Problem of Medicare Fraud

You have to admire the vigilance and dedication of prosecutors and law enforcement investigators who fight Medicare fraud. There is no question that they have ramped up enforcement and promoted a strong message of deterrence. Consider the nature of the problem. The FBI estimates that between five and ten percent of all healthcare expenditures (government and private) are fraudulent. Medicare suffers huge annual losses from...

Senior Associate Needed: The Volkov Law Group

The Volkov Law Group is offering a great opportunity for experienced attorneys seeking a position with a nationally-recognized boutique law firm.  A leader in anti-corruption compliance and defense, the Volkov Law Group offers an innovative work environment with virtual offices on both east and west coasts.  The Firm specializes in ethics and compliance services, including anti-corruption, trade compliance and AML services, as well as white...

NAVEX Global White Paper: “A Holistic Approach to Global Anti-Corruption Compliance”

I am pleased to announce my affiliation with NAVEX Global, and the issuance of a white paper – A Holistic Approach to Global Anti-Corruption Compliance, which is available here. There is no other company (or brand) which carries as much weight in the compliance field – NAVEX Global is a true leader, committed to professional technology solutions for ethics and compliance. NAVEX is the gold...

Putting the Pieces Together: Integrated Due Diligence Programs

One of the many challenges in the compliance profession centers on coordination and integration.  There are plenty of compliance experts who can describe a perfect world – how to design a specific program and procedures to implement the program.  Vendors are ready to line up at a chief compliance officer’s door and sell them products which will carry out a specific program. The challenge for...

The CCO – not the CEO – Creates an Ethical Culture

Consider it one of my (many) pet peeves – companies claim they have an “ethical” culture and cite the consistent statements by the CEO of his or her commitment to “ethics and integrity.”  That’s it, that’s all, we have an ethical culture.  Case closed, deal done, let’s move on to the next issue. Talk about bloviating and hot air – it is the prime example...

Volkov Law Group

The New Volkov Law Group Website

I am pleased to announce the launch of the new Volkov Law Group website (Here), Facebook Page (Here), Linked In Profile (Here) and You Tube Channel (Here). My practice has grown from largely a solo practice to a boutique practice, and currently includes three talented associates.  Our firm focuses on compliance, enforcement defense and internal investigations.     We have created a platform which will assist our...

CCOs as Superheroes: Compliance SWAT Teams

Forgive me for this column in advance but I had to chuckle a little bit when I read that JP Morgan was creating global compliance SWAT teams who, on a moment’s notice, would travel around the globe to respond to compliance emergencies.  I know I have written on behalf of Chief Compliance Officers and the important role they play in every company, but I was...

Vendor/Supplier Due Diligence: Tricky Issues and Twists and Turns

You have to admire chief compliance officers for their tenacity and ability to multi-task.  They are the consummate jugglers of important projects, strategies and tasks.  They can never completely finish their tasks – when one is finished, the list continues to grow with more to dos. Over the last few years, companies have paid more attention to third-party due diligence.  As a result, companies have...

Facing Reality in China

As I have frequently stated, if your business is operating in China, chances are you are violating the FCPA.  That sounds very cynical but there is a measure of reality to my claim. With all the recent attention from the GSK investigation in China which is rapidly extending to other drug companies, China should be on every company’s mind.  There are several important aspects to...