A comprehensive approach to third party and vendor due diligence management is essential for any company conducting business globally.  A strong due diligence program’s purpose is two-fold: To guide your company, helping you make smart choices when it comes to international business partners, and To protect your company, building procedures and a legally-defensible documentary record that can protect you from an enforcement action (udner either...

“Action speaks louder than words but not nearly as often” – Mark Twain If you are too busy to read my posting, all I ask is that you read the Mark Twain quote and apply the message to creating an ethical culture. As I always say, Mark Twain would have been a star Chief Compliance Officer. He was an artist with words, and he used...

A nickel ain’t worth a dime anymore. – Yogi Berra With all the hubbub about ethics and compliance, senior managers somehow are able to escape any focus or responsibility for compliance programs except in a managerial context. Senior managers need to be held accountable for their own personal ethics and compliance performance as senior executives with significant responsibilities. The GM debacle is a perfect example...

Live and Remote In-House Training Programs The Volkov Law Group offers a wide selection of in-house training services for companies. Our training programs are flexibly designed to address a variety of issues and can be customized to address the specific risks facing your company. Past programs include: Code of Conduct Anti-Corruption Anti-Money Laundering Third-Party Due Diligence Merger and Acquisition Due Diligence Export Control and Sanctions...

Companies are reluctant to go to trial in a criminal case.  Instead, they look for alternatives short of a criminal guilty plea and DOJ has a suitcase full of options that they use. Please do not misunderstand my point – DOJ prosecutors are doing their job and they apply the law fairly. There is room for disagreement on their interpretations and application of the law...

The Antitrust Division is nearing the end of its largest, record-setting criminal cartel investigation – global auto parts suppliers. It has been a sprawling investigation that has leaped from product-to-product in the auto parts industry. Nearly thirty companies have plead guilty (or agreed to do so) and over $2.3 billion in fines have been collected. Nearly forty individual have been charged, most of which have...