In episode three of a three-part series, Michael Volkov, who has 25 years experience as a federal prosecutor, reviews the important timeline of events and discusses next steps on Special Counsel Mueller’s investigation.
In part II of his three-part series, Michael Volkov offers his insights and perspective, based on 25 years of services as a federal prosecutor, on the ongoing Russian investigation. In this episode, Michael Volkov focuses on the Michael Flynn plea agreement.
Michael Volkov provides his perspective, based on 25 years as a federal prosecutor, on Special Counsel Mueller’s ongoing investigation of the Trump Administration and potential crimes involving illegal collaboration with the Russian government and obstruction of justice. Michael Volkov provides a fresh overview of the ongoing investigation, and focuses this initial episode on the background and tactics used in the investigation, the Manafort and Gates...
On November 26, 2017, the Justice Department announced adoption of its new FCPA Corporate Enforcement Policy. Deputy Attorney General Rod Rosenstein announced the new policy at an FCPA Conference in Washington, D.C. Under the new policy, corporations that voluntarily disclose potential FCPA violations, fully cooperate with the investigation and implement timely and appropriate remediation will earn a presumptive declination, subject to the absence of aggravating...
Compliance officers have to be mindful of new and emerging threats. In the past few years, cyber security and data privacy have been quickly rising as new and significant threats that corporations face in the global marketplace. The European Union has adopted a far-reaching new regulatory regime applicable to companies that conduct business in the European Union and collect any sensitive data relating to EU...
To implement an effective ethics and compliance program, global companies have to establish an effective internal investigation program. Whether conducting a critical or routine investigation, investigators have to be able to conduct interviews in a fair and effective manner. The success of an internal investigation often depends on the interviews of subjects and witnesses. In this podcast, Michael Volkov reviews his top 10 rules for...
Global companies face ever-increasing risks with sanctions screening and compliance. The US Treasury Department’s Office of Foreign Asset Control (“OFAC”) has aggressively enforced complex sanctions regulations against global companies, including banks, manufacturing, oil service and technology companies. In this aggressive enforcement era, companies have to implement robust screening and compliance controls to identify sanctioned entities and individuals among their business partners and customers. In this...
In a watershed week for FCPA enforcement, the US Department of Justice announced FCPA criminal charges against seven individuals. Specifically, the Justice Department announced four guilty pleas and one indictment as follow on prosecutions to the January 2017 Rolls Royce FCPA enforcement action, and two guilty pleas in a yet to be announced enforcement action against SBM Offshore. The Justice Department’s unprecedented week underscored that...
An effective ethics and compliance program requires a careful assessment of risks and existing controls. In order to design and implement an effective program, a chief compliance officer has to identify and prioritize company risks. In addition, a CCO has to review and understand how existing compliance controls mitigate existing risks. A risk assessment is the foundation of a compliance program, but has to incorporate a...
Global companies and corporate officers and employees face significant criminal antitrust risks. The US Department of Justice’s Antitrust Division has a mature and aggressive enforcement program targeting illegal cartel activity. Unfortunately, companies have been slow to implement ethics and compliance programs that are adequately focused on these serious criminal risks. In this episode, Michael Volkov discusses the need for robust ethics and compliance programs and...
