Chief Compliance Officers Enforcement

News & Analysis as of

[Webinar] What CCOs Need to Know About the SEC’s Recent Focus on Compliance Officers - Sept. 22nd, 1:00 Eastern

The BHP Billiton case represents more than just another FCPA enforcement action; it is a possible landscape change and paradigm shift, one that compliance officers must understand. The SEC charged BHP Billiton $25M for its...more

A Compilation of Enforcement and Non-Enforcement Actions

Non-Enforcement - Form PF — What Purpose? SEC registered investment advisers with at least $150 million of assets under management in private funds are required to periodically file Form PF with the SEC. The...more

Give & Take: The Case for a Better G&E Compliance Program

Part One: Setting The Foundation - Why Does G&E Matter? Tony Robbins once said, “Every problem is a gift—without problems we would not grow.” In the compliance arena, the reverse also applies, as many gifts can...more

SEC Chair Attempts to Reassure Compliance Officers That They Will Not Be Targeted

Demonstrating the effect recent enforcement efforts have had on the industry, in remarks given in Washington, DC at a Compliance Outreach Program for broker-dealers, Securities and Exchange Commission Chairman Mary Jo White...more

FinCEN Reasserts its Commitment to Casino Oversight and Enforcement

In a recent post we described a number of steps taken over the last year by the primary federal regulator for casinos – the Financial Crimes Enforcement Network (FinCEN) – that should cause casino operators to have Title 31...more

FinCEN Reasserts its Commitment to Casino Oversight and Enforcement

In a recent post we described a number of steps taken over the last year by the primary federal regulator for casinos – the Financial Crimes Enforcement Network (FinCEN) – that should cause casino operators to have Title 31...more

DOJ Criminal Chief Warns Financial Institutions about Bitcoin

On June 26, 2015 at the ABA National Institute on Bitcoin and Other Digital Currencies, Assistant Attorney General Leslie Caldwell sent a targeted warning to financial institutions that deal with Bitcoin and other virtual...more

Letter from America: Non-Us Companies And Executives At Risk From Us RICO Law

More frequently than ever before, American plaintiffs and prosecutors are using U.S. laws to target conduct that has little, if any, connection to the United States. Potential exposure to criminal and civil liability under...more

Blog: Key Takeaways from Government Enforcement Panel at ACI Sunshine Conference

Recently, representatives from the United States Attorney’s Office for the Northern District of Georgia, United States Attorney’s Office for the District of New Jersey, and Medicaid Fraud Control Unit (MFCU) for the Office of...more

Top Ten International Anti-Corruption Developments for May 2015

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month with links to primary...more

[Webinar] Transparency after a Compliance Failure: Managing the Risk or Maximizing the Opportunity? - June 16, 1:00 CDT

Every week we read about an organization facing the question of how to respond to a compliance or ethics mistake that has become public. Not so public are the discussions in the background: Should information be shared? If...more

[Webinar] Mexico: The Changing Landscape of Anti-Corruption - June 10, 11 EST

New laws, increased enforcement and broadened liability increase the urgency for companies working in Mexico to put processes in place to prevent corruption within their own organizations and among their business...more

Corporate Investigations & White Collar Defense - May 2015

It’s an Absolute Privilege to Meet You! Texas Supreme Court Rules That Internal Investigation Report Provided by Shell Oil to DOJ Enjoys “Absolute Privilege” - Why it matters: On May 15, 2015, the Texas Supreme Court...more

Robert Appleton: It’s FCPA Compliance or Vegas

Today is the first of a two part interview with Robert “Bob” Appleton and is an edited version of the entire interview which will be available for download when part II is published next week....more

The Sixth Circuit Reins in the Government's Measure of False Claims Act Damages

Pharmaceutical and device companies, financial institutions, government contractors, oil and gas conglomerates, and other public and private entities continue to be in the crosshairs of aggressive federal government...more

DOJ: Companies Need Not Expend Exorbitant Fees to Get Full Cooperation Credit

During an FCPA panel event, the Chief of the US Department of Justice’s Fraud Section advised companies to conduct “targeted” FCPA investigations, dismissing the suggestion that companies must spend hundreds of millions of...more

What is the Current State of Anti-Bribery Compliance & Enforcement in Australia? [Video]

On March 13th, 2015, GRC Solutions hosted a Round-Table discussion with compliance and legal professionals from some of the largest firms in Australia. I was invited as an Anti-Bribery, Compliance and Ethics consultant via...more

[Webinar] Benchmarking Your Policy Management Program - May 21, 10:00am PT / 1:00pm ET

Join this free webinar to hear compelling survey results and answers to questions such as: What are organizations doing to address policy management today? What are E&C leaders’ top policy management...more

DOJ Criminal Division Chief Provides Guidance on Corporate Charging Decisions

On April 17, 2015, Assistant Attorney General Leslie Caldwell provided helpful guidance regarding the Justice Department’s approach to corporate charging decisions in remarks that she delivered at New York University Law...more

Dealing with high-risk clients and final advice for maintaining an effective AML compliance program

Dealing with high-risk clients in an era of enhanced AML enforcement - To identify and trace criminal activity, federal law enforcement relies on the mandatory filing of suspicious activity reports (SARs) by financial...more

Applications like WhatsApp are reshaping government investigations and should be refocusing how compliance departments handle...

White Collar, Regulatory Defense, and Investigations Client Update - In today’s high tech world, the ways to communicate are almost limitless. This presents risks for organizations and challenges for compliance...more

Assuring Regulatory Compliance Doesn’t Get Lost in Translation

With the expansion of large multinational corporations into developing countries such as Russia, Brazil, India, Mexico and China, a proliferation of global regulatory enforcement actions, including anti-bribery and...more

FCPA Compliance and Ethics Report-Episode 145-SEC Enforcement of the FCPA, Part II [Video]

In this episode which is Part II of my look at SEC enforcement of the FCPA, I consider whether profit disgorgement is available to the SEC in a strict liability enforcement action of violation of internal controls. ...more

The Gathering Momentum of Anti-Bribery Enforcement in Australia

Today’s interview is with Julian Fenwick and Jane Ellis, both Anti-Bribery Compliance Professionals in Australia. Given the recent reporting concerning anti-bribery, corruption, and compliance issues in Australia, I thought...more

Miss Marple Short Stories and SEC Enforcement of the FCPA, Part I

I am a huge Agatha Christie fan. I have read most of the Poriot novels and many of the Jane Marple novels as well. However, I was not aware of Christie’s work in the short story format until I recently read a volume entitled...more

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