Steps Your Nonprofit Can Take to Mitigate Fraud Risks - Part 2
Implications of the SEC Cybersecurity Disclosure Rule
Why Time Matters: Partners Lindsay Gerdes and Michael J. Bronson on Swift Action in Government Investigations
Privacy Issues from Third-Party Website Tags
False Claims Act Insights - If Everything Matters, Nothing Does: Parsing Materiality in FCA Disputes
Episode 331- NAVEX State of Risk and Compliance Programs
What the Board Should Be Asking About the Compliance Program
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
Managing Social Media Risk
FCPA Compliance Report: Erica Salmon Byrne on Closing The Speak Up Gap
Principled Podcast: S11E7 | Fortifying Ethical Frameworks: Navigating Emerging Risks in the Middle East
Episode 327 -- Another Look at the Importance of Corporate Culture
In Brief: Election Law & Government Ethics Unpacked: National Convention Guidance
Episode 320 -- NAVEX Hotline Report -- More Reports and Higher Substantiation
Episode 318 -- LRN's Recent Study Underscores Importance of Ethical Culture and Values-Based Leadership
Principled Podcast: S11E6 | Ethics & Compliance Evolution in Singapore: Adapting to Global Risks
Episode 315 - Boeing Pays $51 Million for ITAR Violations
Episode 312 -- Eddie Green, CEO SnippetSentry, on Communications Preservation Risks
Behavioral Health Compliance
The EU Whistleblowing Directive
Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more
RULEMAKING AND GUIDANCE - SEC Adopts Amendments to Exemptive Applications Procedures - On July 6, 2020, the U. S. Securities and Exchange Commission adopted rule amendments to establish an expedited review procedure...more
This week I am exploring the Wells Fargo Department of Justice (DOJ) and Securities and Exchange Commission (SEC) settlement of $3 billion. The case presents multiple lessons for the compliance professional and one very large...more
If adopted efficiently, the PDPC’s Ethical Accountability Framework should help organizations to demonstrate and enhance trust with individuals. In October, 2018, Hong Kong’s Privacy Commissioner for Personal Data (PCPD)...more
You really do have to appreciate Wells Fargo & Co. Perhaps solely of the most recent spate of US corporate ethics scandals, it is the company that keeps giving and giving and giving. On the other hand, it may simply be that...more
The normal view of undue influence involves an actor threatening an elderly or infirm person into signing a document that he or she otherwise would not sign. One imagines the actor having control over the person and threating...more
The quasi-legal status of marijuana in today’s United States is raising serious questions about federalism and enforcement for U.S. financial institutions. It is well known that marijuana is still classified as a Schedule I...more
In this month's edition of our Privacy & Cybersecurity Update, we examine the European Commission's second annual review of the Privacy Shield and the Department of Commerce's guidance on how to comply with the Privacy Shield...more
In this month's edition of our Privacy & Cybersecurity Update, we examine a declaration on ethical considerations for artificial intelligence, the annual joint review of the Privacy Shield, a new lawsuit from a snack food...more
Maybe I am missing something, but everyone is jumping on the culture bandwagon. Regulators like to speak about it; prosecutors like to emphasize it – everyone likes to talk about it as a way to encourage corporate leaders to...more
Federal prosecutors and regulators have been active in tackling US banks. In the last few weeks, the Federal Reserve took the extraordinary step of blocking Wells Fargo’s ability to grow its business until it improves its...more
HSBC’s making good on its plans to shift to a focus on Asia by naming John Flint—who spent his first 14 years at the bank in Asia—as its new CEO. Flint will take over from Stuart Gulliver in February....more
Klaus Kleinfeld is out as CEO of Alcoa-subsidiary Arconic. Kleinfeld’s two-year tenure was marked by problems, and Kleinfeld did himself no favor with an un-Board-authorized letter that he sent to activist-investor Elliott...more
Following up on news last week that Bill Ackman was finally done with his grand Valeant experiment, the Times gives us a deeper look at what was really going on with the activist investor’s bet and ultimate $4 billion loss....more
OCIE Highlights Frequent Topics for Compliance Deficiencies for Investment Advisers - On Feb. 7, 2017, the Securities and Exchange Commission’s (SEC’s) Office of Compliance Inspections and Examinations (“OCIE”) published...more
I recently read an article in the MIT Sloan Management Review, entitled “How Blockchain Will Change Organizations”, where authors Don Tapscott and Alex Tapscott speculate that the transformations which blockchain may...more
On October 24, 2016, OCIE published a risk alert noting that the SEC exam staff intends to examine registrants' compliance with the Dodd-Frank Act's whistleblower provisions. The alert noted recent enforcement actions...more
In October 2015 the Financial Conduct Authority (FCA), alongside the Prudential Regulation Authority (PRA), published new rules in relation to whistleblowing channels in banks and other financial institutions to encourage a...more
Tennessee has joined other states in formally approving lawyers’ cloud-storage of client-confidential data. The Board of Professional Responsibility (“BOPR”) held that lawyers ethically may use cloud storage for...more
Failure to disclose conflicts of interest and/or to comply with firm procedures are the predicates for a series of SEC enforcement actions involving regulated entities. The most recent example of these trends is an action...more
As we come to the close of the Obama Administration, the Justice Department will certainly be able to point to its record of aggressive white-collar enforcement in a variety of areas. One glaring claim omission from that list...more
Carlton Fields Jorden Burt’s Government Law and Consulting Practice Group released its 2015 Florida Legislative Post-Session Report detailing significant bills that passed during the 2015 Regular Session of the Florida...more
On this day in 1899, Ernest Hemingway was born. To me, he was the greatest Man of Letters the US has produced. Probably like most of you all, I was introduced to Hemingway in high school through The Son Also Rises. It remains...more
I have to confess that there is a part of me that was skeptical about a new survey released last week finding that banks and other financial institutions have not embraced a culture of integrity. Indeed, the survey found...more