Implications of the SEC Cybersecurity Disclosure Rule
The Privacy Insider Podcast Episode 4: Don't Be Evil: In the Hot Seat of Data Privacy, Part 1
Privacy Issues from Third-Party Website Tags
Episode 331- NAVEX State of Risk and Compliance Programs
What the Board Should Be Asking About the Compliance Program
Managing Social Media Risk
Compliance Lessons from Dating in Your 50s
Managing Compliance Risk for Human Trafficking and Modern Slavery
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
False Claims Act Insights - The Art and Science of Corporate Compliance in Managing FCA Risk
Preparing for a Government Healthcare Audit
Episode 318 -- LRN's Recent Study Underscores Importance of Ethical Culture and Values-Based Leadership
Understanding the HHS OIG’s General Compliance Program Guidance
Climate Risk, the emerging risk
What's Going on with FCPA?
Compliance, Project Management, and Process Improvement
Leaning in on AI in Compliance Programs
PODCAST: Williams Mullen's Gavels & Gowns - Title IX Regulations - Changes on the Horizon
Episode 312 -- Eddie Green, CEO SnippetSentry, on Communications Preservation Risks
Behavioral Health Compliance
Our Investment Funds Group reviews the implications of a Commodity Futures Trading Commission (CFTC) policy targeting chief compliance officers (CCOs) as individuals if their companies’ compliance programs fail....more
According to the Institute of Internal Auditors “Politics of Internal Auditing” (2015), 55% of chief audit executives were directed to commit important findings from their audit reports. 49% of chief audit executives were...more
After issuing two proposals, the Securities and Exchange Commission (SEC) adopted final rules (Final Rules) to establish its trading regime for security-based swaps (SBS) as required under the Dodd-Frank Wall Street Reform...more
On October 17, the Commodity Futures Trading Commission’s Division of Enforcement released an advisory instruction to CFTC staff for future enforcement actions. The advisory provided guidance on the following: (i) whether...more
In 2022, the DOJ and the SEC resolved a total of ten corporate enforcement actions under the FCPA, more than double the number in the previous year. While the average corporate penalties only slightly increased to $168...more
On March 27, 2023, the Commodity Futures Trading Commission (“CFTC”) filed a civil enforcement action against three entities that operate a digital asset exchange (the “Company”) and its Founder and Chief Executive Officer...more
The Commodities and Futures Trading Commission (CFTC) has become the latest regulatory agency to spell out what it wants corporate compliance programs to accomplish in the form of a two-page memo, published Sept. 10, 2020,...more
Investment advisers registered with the U.S. Securities and Exchange Commission (SEC) or with a state, as well as commodity pool operators and commodity trading advisors registered with the U.S. Commodity Futures Trading...more
Enforcement activity reached new heights in 2019. The year saw the two largest corporate resolutions in the history of the FCPA, corporate penalties paid to US enforcement agencies topped last year’s record levels, and...more
A non-US-based investment and brokerage firm agreed to settle spoofing allegations by the Commodity Futures Trading Commission by payment of a US $700,000 fine. In accepting this settlement, the CFTC emphasized the...more
The Commodity Futures Trading Commission (CFTC or Commission) at year-end issued one final and two proposed rulemakings. The proposed rules are potentially significant for all swap market participants, and the final rules are...more
The Commodity Futures Trading Commission issued revised guidance for mandatory chief compliance officer annual compliance reports for futures commission merchants and swap dealers. However, the proposed recommendations are...more
On September 12, 2019, the Commodity Futures Trading Commission (CFTC) announced a settlement with Phillip Capital Inc. (PCI or the “Company”), a registered futures commission merchant (FCM), after hackers successfully...more
Last week, the Commodity Futures Trading Commission publicized a cascade of settlements of enforcement actions alleging breaches of laws and rules related to supervision, spoofing, reporting, and misappropriation of...more
The U.S. Commodity Futures Trading Commission (“CFTC”) sent a strong message to Chief Compliance Officers (“CCO”) this week when it held a CCO held accountable for lying to the National Futures Association (“NFA”) during an...more
The Commodity Futures Trading Commission (CFTC) has proposed the first installment of a series of amendments to its rules relating to swap data repositories (SDRs) and reporting of swap data. The proposed amendments, which...more
A swap dealer was fined US $12 million by the Commodity Futures Trading Commission for a host of purported noncompliance issues. It was also sanctioned for allegedly not disclosing in two annual chief compliance officer...more
On August 27, 2018, the Commodity Futures Trading Commission (“CFTC”) published final rules in the Federal Register amending its regulations regarding duties of chief compliance officers (“CCOs”) of swap dealers (“SD”), major...more
U.S. Financial Industry Developments - SEC Disapproves the Listing and Trading of Nine Bitcoin Related Exchange Traded Products - On August 22, 2018, the SEC released three Orders, acting through authority delegated to...more
On August 21, 2018, the Commodity Futures Trading Commission (“CFTC“) unanimously approved final amendments clarifying and simplifying its regulations governing chief compliance officer (“CCO“) duties and annual compliance...more
The Commodity Futures Trading Commission revised its rule related to the responsibilities of chief compliance officers of futures commission merchants, swap dealers and major swap participants, as well as the obligations of...more
On May 3, 2017, the Commodity Futures Trading Commission (“CFTC”) approved for publication in the Federal Register proposed amendments to its rules regarding the duties of Chief Compliance Officers (“CCOs”) for swap dealers...more
Financial Industry Developments - CFTC Proposes to Amend Rules Governing Chief Compliance Officer Duties and Annual Reports for Certain Registrants - On May 3, 2017, the U.S. Commodity Futures Trading Commission...more
On May 3, 2017, the U.S. Commodity Futures Trading Commission (CFTC) announced that it will publish in the Federal Register proposed amendments to Part 3 of its regulations. The proposed amendments would (1) define “senior...more
I am astonished there are still so many articles out there advising readers on how to establish the imperative for compliance. Nearly 15 years after the rise of compliance to an officer-level position, with significant...more