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Day 19 of 30 Days to a Better Compliance Program-Compliance Expertise on the Board [Video]

Every Board of Directors need a true compliance expert sitting on their Board. Almost every Board has a former Chief Financial Officer (CFO), former head of Internal Audit or persons with a similar background and often times...more

Day 18 of 30 Days to a Better Compliance Program-Email Sweeps [Video]

Ongoing monitoring is not limited to the financial component of compliance. The concept is straightforward; at regular intervals you can sweep through your company email database for identified key words that can be flagged...more

Day 17 of 30 Days to a Better Compliance Program-Uncovering Shell Companies [Video]

One of the more prescient authors I know is Ryan C. Hubbs, who in 2014, wrote an article for Fraud Magazine entitled “Shell Games”. Shell companies can come in different shapes and sizes. Shelf companies are those formed but...more

The Obama Administration Eases Sanctions Against Sudan

On January 13, 2017, the White House, the U.S. Department of Treasury ’s Office of Foreign Assets Control (OFAC) , and the U.S. Department of Commerce ’s Bureau of Industry and Security (BIS) announced a host of policy...more

Hogan Lovells Global Payments Newsletter l January 2017

Welcome to the Hogan Lovells Global Payments Newsletter. In this monthly publication we provide an overview of the most recent payments, regulatory and market developments from major jurisdictions around the world as well as...more

Compliance into the Weeds-Episode 25 [Video]

In this episode Matt Kelly and I take a deep dive into a couple of recent SEC enforcement actions. The first involved L-3 Technologies and accounting irregularities. The second involves BlackRock and the continued issues...more

Day 15 of 30 Days to a Better Compliance Program-Post Training Evaluation [Video]

What if you want to take you post-training analysis to a higher level and begin to consider the effectiveness through your return on investment (ROI)? Joel Smith, the founder of Inhouse Owl, a training services provider,...more

Day 14 of 30 Days to a Better Compliance Program-Design of Your Compliance Training Program [Video]

For compliance training to be effective its needs to risk-based in its focus. This means employees with highest risk of exposure to bribery and corruption need to receive the highest levels of training and refreshers. From...more

This Week in FCPA-Episode 35-the Friday the 13th edition [Video]

Show Notes for Episode 35, week ending January 13, the Friday the 13th edition   1.       Hernandez and Beech FCPA guilty pleas. 2.       VW guilty plea in emissions-testing scandal. 3.       VW executive Oliver...more

Day 13 of 30 Days to a Better Compliance Program, create a data action plan [Video]

You should work to create an action plan to use your data. But never forget you need to get your digital information right. That means several sources of data to help you choose the best course of action. Earlier this year,...more

Day 12 of 30 Days to a Better Compliance Program, creating a culture of data in compliance [Video]

You should work to create a culture of data in your compliance program. This comes from an understanding that data is a product, which you can consume internally in the compliance function. Your data is a corporate asset so...more

Expect the Unexpected: The Year Ahead for the Financial Institutions Sector

With contributors across the sector and the globe, we've compiled a review of some of the developments that will affect financial institutions in 2017 and beyond. The one thing that 2016 taught us was to expect the...more

DIFC to Launch FinTech Hive

The Dubai International Financial Center (DIFC) is set to launch the FinTech Hive—an accelerator program for developing financial technology (fintech) start-ups and entrepreneurs—in the first quarter of 2017. The FinTech Hive...more

Compliance into the Weeds-Episode 24 [Video]

In this episode Matt Kelly and myself take a deep dive into the compliance weeds by looking at a paper written by then SEC General Counsel James Doty (later head of the PCAOB) in 2007 where he proposes a regulatory scheme for...more

Day 10 of 30 Days to a Better Compliance Program, Mergers and Acquisitions [Video]

A company that does not perform adequate due diligence prior to a merger or acquisition may face both legal and business risks. Perhaps, most commonly, inadequate due diligence can allow a course of bribery to continue - with...more

Day 9 of 30 Days to a Better Compliance Program, Continuous Improvement [Video]

No area has become more challenging in compliance than continuous improvement. The FCPA Guidance specifies that “a good compliance program should constantly evolve. A company’s business changes over time, as do the...more

Day 8 of 30 Days to a Better Compliance Program, Reporting and Investigations [Video]

The FCPA Guidance has about as clear, concise and short a statement about hotlines than any other Tenet of an Effective Compliance Program. It states, “An effective compliance program should include a mechanism for an...more

Day 7 of 30 Days to a Better Compliance Program, Third Parties [Video]

Day 7- Third-Parties There are five steps in the life cycle of third party management. 1. Business Justification and Business Sponsor; 2. Questionnaire to Third Party; 3. Due Diligence on Third Party; 4. Compliance...more

This Week in FCPA-Episode 34-the Invisible Hand edition [Video]

In this episode Jay Rosen and I take a dive into the General Cable FCPA enforcement action, consider the 'Invisible Hand' of Justice Department Compliance Counsel Hui Chen and greater regulatory enforcement, corporate...more

Day 6 of 30 Days to a Better Compliance Program, Carrots and Sticks [Video]

The FCPA Guidance states, that “In addition to evaluating the design and implementa­tion of a compliance program throughout an organization, enforcement of that program is fundamental to its effec­tiveness. A compliance...more

Day 5 of 30 Days to a Better Compliance Program, Communications and Training [Video]

Welcome to Day 5 of 30 Days to a Better Compliance Program. Today, I focus on training, ongoing communications and the use of social media in a best practices compliance program. Training The communication of your...more

Your Daily Dose of Financial News

The Fed’s anticipating faster growth in the coming year and rate increases to go with it. That and a whole lot of uncertainty about the incoming administration are the big takeaways from the Fed’s December meeting minutes....more

Cryptocurrencies - prompt contrasting reactions by Latin American regulators

While used by organized crime, cryptocurrencies are also becoming accepted as a legitimate payment method by mainstream sectors of the economy in Latin America. Currently, some stores, start-ups, restaurants, hotels, and...more

Badda Bing, Badda Boom!! — DOJ and SEC Make 2016 a Record Year for FCPA Enforcement (Part I of III)

We begin the New Year with a three-part series on the FCPA: (1) A review of FCPA enforcement in 2016; (2) Trends from 2016 FCPA enforcement; and (3) Predictions for FCPA enforcement in 2017....more

Compliance into the Weeds-Episode 23, Six Compliance Issues to Consider in 2017 [Video]

In this episode, Matt Kelly and I consider six compliance-related issues every compliance practitioner should watch in 2017. ...more

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