Our Practice Areas
White Collar Defense
We zealously defend our clients – whether individuals or businesses – before federal regulatory bodies. We have represented clients before the Department of Justice (DOJ), the Federal Bureau of Investigation (FBI), various US Attorney’s Officers, state and local courts, and more. As a former federal prosecutor, Michael Volkov has the experience to handle the most difficult cases. This extensive experience allows us to craft comprehensive strategies to navigate the process.
- Federal Investigations
- FCPA Anti-Corruption
- False Claims Act
- Healthcare Fraud
- Cybercrimes and Data Privacy
- Administrative Actions
- Represented Lt. Col. Alexander Vindman through private deposition and public hearing, as key witness in 2019 Presidential impeachment proceedings.
- Guided national nonprofit through high-profile government investigation concerning national security matters relating to alleged espionage from a foreign adversary.
- Guided multiple individuals through phases of the DOJ Antitrust Division’s Leniency program resulting from alleged international cartel activity, obtaining leniency letters for all.
Corporate Compliance and Ethics Programs
A strong compliance program structured around an up-to-date risk assessment protects an organization by detecting and preventing improper conduct, promoting adherence to the organization’s legal and ethical obligations, and mitigating the severity of an investigation or penalty under the DOJ’s Corporate Enforcement Policy. Companies with a positive ethical culture have lower rates of employee misconduct, increased employee productivity, and lower employee turnover.
Our firm is a recognized global leader in the field and we specialize in providing cost effective solutions tailored to the unique needs of each of our individual clients. Our recommendations are designed to meet or exceed federal guidance and incorporate industry best practices.
- Risk Assessments
- Policy Design and Management
- Third Party Management
- Board Engagement and Training
- Culture Surveys
- Merger/Acquisition Due Diligence and Integration
- Conducted global anti-corruption compliance audit of Fortune 500 healthcare company in response to DOJ FCPA investigation. Reviewed and tested compliance controls, books and records, and transactions.
- Conducted numerous anti-corruption and FCPA compliance training for various clients, focusing on risks specific to Europe, Latin America, and Africa, in addition to the United States.
- Ongoing due diligence reviews of potential joint venture partners for Fortune 500 company involved in global concession operations at international travel hubs. Developed a due diligence review and contracting process for joint venture partners, including questionnaire, contractual provisions, and memoranda needed to support creation of joint venture, monitoring of joint venture operations, and other support services.
Export Controls and Trade Sanctions
The United States maintains a complicated web of export control laws and regulations that operate to restrict the use of and access to controlled information, goods, and technology for reasons of national security or protection of trade. The U.S. generally restricts the export of dual-use goods and technology (i.e. items that have both a civilian and potential military application), defense articles, nuclear materials and technology, and items that would assist in the development of weapon or missile technology. The U.S. also restricts exports to certain countries, such as Cuba, Iran, and Syria, and OFAC maintains a system of sanctions known as list-based sanctions against specifically-designated persons and entities.
- Specific License Requests
- Voluntary Disclosures
- Export Classifications
- Export License Requests
- Sanctions Compliance Program Design
- CFIUS Reviews
- Reviewed multi-million dollar transactions and counseled on sanctions matters on various projects including Russia’s LNG fields, Iran’s wind-down periods, and the Venezuela General Licenses, including multiple Specific License applications.
Third Party Risk Management
Companies rely on a network of third-party actors, including vendors, suppliers, logistics, professionals, lobbyists, and other entities. We can review existing third-party risk management programs, including its use of third parties in a representative capacity, the nature and extent of third-party interactions with foreign government representatives, reliance on other third parties for operations, and any other relevant third-party actors. With respect to third-party risk management, our focus will include and not be limited to the following specific areas: (i) customs and border risks; (ii) manufacturing operations; (iii) government interactions; (iv) countries of operation; and (v) annual revenues.
- Onboarding Process Design
- Due Diligence Reviews and Reports
- Supply Chain Risk Management
- Third Party Risk Rating
- Trainings and Communications
- Performed risk assessment of high-risk third party distributors for Fortune 500 appliance manufacturing company. Risk rated over 100 counterparties and provided guidance on improving overall onboarding procedure.
- Conducted third-party due diligence audit of over 400 global business partners for a Fortune 500 logistics company. Conducted refreshed due diligence on nearly 150 parties identified as receiving defective reviews.
Anti Money Laundering
We can help our clients develop a system of internal controls, policies, and procedures designed to ensure ongoing compliance with all applicable anti-money laundering laws, rules, and regulations. We work with traditional financial institutions, FinTechs, VASPs, cryptocurrency companies, and more.
We have conducted internal investigations for companies on a variety of matters relating to potential violations of state and Federal law, as well as internal Codes of Conduct issues. When a company suspects a violation, deciding whether to disclose the violation, and how to implement the proper remedial measures, cannot be left to chance if costly and damaging enforcement actions are at stake.
Utilizing investigative skills and techniques gained over more than 30 years of collective experience in the government and in other industries, our team will ensure that your company gets to the bottom of a putative violation.