News & Analysis as of

CCO

Protecting Privilege of the Corporate Compliance Officer

by Baker Donelson on

The Corporate Compliance Officer (CCO) acts as the organizational conscience overseeing the compliance program. Corporate integrity promotes a strong brand reputation, avoids high-profile failures and contributes to a strong...more

The Power of Honesty – A Candid Assessment of Your Compliance Program

by Michael Volkov on

The secret of life is honesty and fair dealing. If you can fake that, you’ve got it made.  Groucho Marx - We are all taught the importance of honesty. But there are very different aspects to this otherwise simple...more

Compliance Expertise Needed on the Board

by Thomas Fox on

This week I have been exploring the different types compliance committee’s which an organization can utilize to help effect a best practices compliance program. I have written about compliance committee’s at the Board of...more

Hiding Behind the Privilege – A Cloak or a Dagger?

by Michael Volkov on

CCOs face many challenges in their jobs. One area that is difficult but usually can be solved with common sense is where to draw the line on attorney-client privilege issues. As a practicing attorney, I can attest to the...more

Top 10 Ethics & Compliance Predictions and Recommendations for 2017

by NAVEX Global on

Once again it’s time for our annual review of trends and events that will impact your Ethics and Compliance (E&C) program in the year ahead. This year presents a unique challenge. We are preparing our predictions...more

BSA/AML Violations Trigger $215M Consent Order With New York's DFS

Violations of state anti-money laundering laws tripped up the Agricultural Bank of China, which recently entered into a consent order with New York's Department of Financial Services for $215 million....more

Manatt on Health Reform: Weekly Highlights - November 2016 #2

CMS authorizes Massachusetts waiver supporting transition to a Medicaid ACO model; Oregon CCOs use “flexible service” funds to invest in housing-related services; and enrollment for 2017 Marketplace coverage begins....more

[Webinar] 2016 Ethics & Compliance Virtual Conference - Harnessing the Business Value of an Ethical Culture - November 15th,...

by NAVEX Global on

Join professionals in ethics and compliance, human resources, legal, audit and training for the annual 2016 Ethics & Compliance Virtual Conference! Learn strategies to help you build a better governed, more risk-aware, and...more

Oregon Requests $1.25 Billion from CMS to Expand Medicaid Coordinated Care Model Demonstration Waiver

by King & Spalding on

Oregon has requested $1.25 billion in federal funding to expand the Oregon Health Plan (OHP), a coordinated care model implemented under Section 1115(a) of the Social Security Act. The current OHP Section 1115 demonstration...more

SEC Enforcement Chief Andrew Ceresney Discusses CCO Liability

by McGuireWoods LLP on

On November 4, 2015, Andrew Ceresney, director of the Securities and Exchange Commission’s (SEC’s) Division of Enforcement (Enforcement Division), delivered the keynote address at the 2015 National Conference of the National...more

Top Ten Resources for Engaging Your Board in Your Ethics & Compliance Program

by NAVEX Global on

Resources to help you engage your board of directors in the success of your ethics and compliance program. A successful board engagement strategy can help ethics and compliance professionals gain significant program...more

SEC Issues Settled Enforcement Action Against Investment Adviser, its President and Senior Officers for Compliance Program...

by Dechert LLP on

The U.S. Securities and Exchange Commission (SEC or Commission) issued a cease and desist order (Order) on June 23, 2015, against Pekin Singer Strauss Asset Management Inc. (Adviser), an investment adviser registered under...more

SEC Proposes to Amend Form ADV and Investment Adviser Recordkeeping Rules

by Dechert LLP on

The U.S. Securities and Exchange Commission (SEC or Commission) recently proposed amendments to Form ADV and to Rule 204-2 (Recordkeeping Rule) and other rules under the Investment Advisers Act of 1940, as amended (Advisers...more

Senn Interview, Part I – Investigations Under the FCPA

by Thomas Fox on

One of the things that I am questioned on is when to bring in outside counsel for a Foreign Corrupt Practices Act (FCPA) investigation or simply to take a look at an issue that may have raised a Red Flag but is not yet a FCPA...more

The Financial Report - Volume 4, No. 7 • April 2015 (Global)

by DLA Piper on

Discussion and Analysis - Last week, the Securities and Exchange Commission proposed to amend SEC Rule 15b9-1 under the Securities Exchange Act of 1934, which exempts certain broker-dealers from membership in a...more

"The SEC’s Private Equity Enforcement Concerns"

On January 23, 2013, Bruce Karpati, Chief of the Asset Management Unit (the “AMU”) of the Enforcement Division of the Securities and Exchange Commission, addressed the Private Equity International Conference in New York. Mr....more

Leadership Lessons for the Compliance Practitioner from Abraham Lincoln

by Thomas Fox on

The recent film about Abraham Lincoln has focused the nation’s attention once again on the President that many believe was our greatest President. In a recent article in the New York Times (NYT), entitled “Lincoln’s School of...more

Leadership in the Compliance Function – Do You Encourage or Stifle?

by Thomas Fox on

There are many ways for a Chief Compliance Officer (CCO) to exercise leadership in not only the compliance function but also across the many disciplines in which compliance impacts in any corporation. In this Sunday’s New...more

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