Chief Compliance Officers

News & Analysis as of

Benchmarking Your FCPA Compliance Program

After a relatively slow year of Foreign Corrupt Practices Act (FCPA) prosecutions in 2015, this year started out with a landmark settlement against telecommunications provider VimpelCom Ltd. DC Partner Mark Srere, Denver...more

NYDFS Issues Final Rule Requiring Certification of Compliance With AML Transaction Monitoring and Filtering Program Requirements

The New York Department of Financial Services (NYDFS) recently finalized a regulation that mandates detailed elements of the anti-money laundering (AML) transaction monitoring and sanctions filtering programs of covered...more

New York Department of Financial Services Issues New AML and Sanctions Regulations

The New York DFS finalized its new AML and Sanctions screening regulations. Interestingly, the NYDFS backed off its original proposal to require a Chief Compliance Officer to certify to a compliance “finding” that the...more

Securities Enforcement: 2016 Mid-Year Review

The Securities and Exchange Commission (the SEC or the Commission) brought over 400 enforcement actions in the first half of 2016 and is on pace to surpass its record of 807 enforcements actions in a single fiscal year, which...more

SEC Issues Guidance on Business Continuity Planning for Registered Investment Companies

On June 27, the staff of the Securities and Exchange Commission’s (Commission or SEC) Division of Investment Management (IM) issued a Guidance Update on business continuity planning for registered investment companies...more

The SEC’s Customer Protection Rule Initiative and Whistleblower Protection Efforts – What Broker-Dealers Need to Know

On June 23, 2016, the SEC instituted a settled enforcement action against Merrill Lynch, Pierce, Fenner & Smith Inc. and Merrill Lynch Professional Clearing Corp. (collectively, “Merrill”), in which Merrill agreed to pay $415...more

Innovation in Compliance – Part III: Design Thinking

I continue to explore innovation in the compliance function by considering how design thinking can help the Chief Compliance Officer (CCO) move forward in an innovative cutting edge manner to make a compliance program not...more

Issuing final rule for financial institutions, NYDFS steps back from threat of criminal consequences for executives

The New York Department of Financial Services (DFS) has issued a final rule, to take effect on January 1, 2017, requiring regulated institutions to adopt risk-based programs to monitor and filter transactions for potential...more

Innovation in Compliance Week, Part II-Superforecasting

I continue my Innovation in Compliance series today by discussing “superforecasting” and its use by a compliance function. Imagine that as a Chief Compliance Officer (CCO), you could create a team which might well...more

An Organizational Response to Global Compliance Challenges

The following is part II of a guest post by Alison Taylor and James Cohen. A consensus has emerged as to what an effective anti-corruption compliance program looks like – its components and success factors. At the same...more

Harry Potter, Whistleblowers and Compliance

One of the things I have enjoyed for years is listening to some of America’s top professors and academics that teach in their subject area of expertise through lectures from the Teaching Company. I just completed the 24...more

SEC Issues Guidance on Fund Business Continuity Planning

On June 28, 2016, the SEC’s Division of Investment Management issued a Guidance Update titled, Business Continuity Planning for Registered Investment Companies (the “Guidance,” available here). The Guidance states that a fund...more

The King’s Guitarist and Leadership

We recently lost some legendary musicians. Last week two of the biggest from very different genres left us. They were Scotty Moore and Dr. Ralph Stanley. Today I want to pay tribute to Scotty Moore, recognized by Rolling...more

Global Boardroom Risk Solutions Newsletter

“Risk is sexy?” - Anonymous GC - Not every Director or General Counsel (GC) is likely to describe risk analysis as “sexy” but there is little doubt that risk issues have demanded a board level focus which would have been...more

When Lawyers Get in the Way of Compliance

I hate to pick on lawyers. I have been practicing law for nearly 35 years. I have worked with and met a lot of lawyers, some great, some good and some not so good. Lawyers can sometimes be their own worst enemies. When...more

Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA) / FCPA Digest

Shearman & Sterling’s bi-annual Trends & Patterns report provides insightful analysis of recent enforcement trends and patterns in the US, the UK, and elsewhere as well as helpful guidance on emerging best practices in FCPA...more

Convergence of Audit and Compliance Functions

Returning to the serious subject of compliance, there are some who argue that compliance is a lot simpler than professionals and commentators tend to describe. I am an advocate for simplicity as a way to ensure adoption of...more

Compliance Meaningfulness: Hard to Achieve, Easy to Destroy

In an article titled, What Makes Work Meaningful- Or Meaningless by Catherine Bailey and Adrian Madden (MIT Sloan Management Review, Summer 2016), the authors focus upon what makes our work meaningful, with research...more

Next on the SEC regulatory agenda: a chief valuation officer?

First, the Securities and Exchange Commission required funds to designate a chief compliance officer. Then, the SEC proposed that funds designate a liquidity risk manager, and after that, a derivatives risk manager. Can a...more

The UK Bribery Act: SFO Procedures and DPA Process

A couple of recent articles about the UK Serious Fraud Office (SFO) caught my attention. One was on thebriberyact.com, entitled “Opinion: DPA’s must show greater benefits. We discuss the Criteria & Process for a DPA set out...more

Good-Bye to Mr. Hockey and Curiosity in a CCO

Gordon ‘Gordie’ Howe died last week. To most of North America he was simply known as “Mr. Hockey”. In his first hockey career, he played in a by-gone era of what we now call the ‘Original 6’ where two Canadian teams and four...more

A Rush to Compliance: Patience is a Virtue

Compliance officers are, by definition, goal driven. They are high achievers and expect to succeed. So what. You may say – we all know that. Compliance officers are not the most patient group of people. They want to see...more

[Webinar] How do I Keep All My Employees—From Millennials to Boomers—Engaged with Compliance Training? - June 24th, 10:30am...

Join NAVEX Global and a group of your peers for a short session where we’ll answer your questions and share solutions about Ethics & Compliance Training....more

[Webinar] Why Do I Need Multiple Intake Methods for Incidents? - June 17th, 10:30am PT/1:30pm ET

Join NAVEX Global and a group of your peers for a short session where we’ll answer your questions and share solutions about incident management reporting....more

FCPA Compliance and Ethics Report-Episode 258-using data, data analytics and data analysis in your compliance programs [Video]

In this episode, I consider how a CCO can use data in a best practices compliance program. ...more

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