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Fraud Policies and Procedures

Fraud is the making of false representations or engaging in deceptive behavior in order to unlawfully secure financial or personal gain. 
Proskauer Rose LLP

SEC Enforcement Action Underscores Need for MNPI Policies in CLO Trading

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In a significant enforcement action, the SEC sanctioned a private fund manager for failing to establish and maintain adequate policies and procedures to prevent the misuse of material nonpublic information (MNPI) while...more

Mitratech Holdings, Inc

The State of Ethics Hotlines in 2024

Leveraging 40,000 anonymous ethics hotline reports and expansive customer interviews, Syntrio’s latest analysis uncovers trends in misconduct, reporting, and more...more

Awatif Mohammad Shoqi Advocates & Legal...

How Can Managers Be Lawfully Removed under the Commercial Companies Law in the UAE?

In the UAE, the process for lawfully removing a manager from a company is governed by Federal Decree-Law No. 32/2021 on Commercial Companies. This comprehensive legislation outlines the procedures and requirements for the...more

Proskauer - The Capital Commitment

Mid-Year Enforcement Update: SEC’s Continued Focus on Private Funds in 2024

As we reach the midpoint of 2024, the SEC has maintained its rigorous enforcement stance on the private funds industry, proposing new rules and oversight tools to better identify and investigate market practices. As 2024...more

Akin Gump Strauss Hauer & Feld LLP

Senate AI Working Group Releases Long-Anticipated Roadmap for AI Policy

On May 15, 2024, the Senate AI Working Group—Senate Majority Leader Chuck Schumer (D-NY) and Sens. Mike Rounds (R-SD), Todd Young (R-IN), and Martin Heinrich (D-NM)—issued their long-anticipated Roadmap for Artificial...more

Society of Corporate Compliance and Ethics...

[Virtual Event] ESG and Compliance Conference - June 18th, 8:00 am - 5:00 pm CT

Achieve your ESG goals in 2024 - Environment, Social, and Governance (ESG) is a top priority for organizations of all types and sizes, and it the compliance team is a key factor in the ESG equation. Much like regulatory...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Mintz

EnforceMintz — DOJ’s Continued Focus on Individual Accountability

Mintz on

As discussed in EnforceMintz – Significant 2022 Regulatory and Policy Developments, the Department of Justice (DOJ) issued several memoranda in late 2022 and early 2023, reinforcing DOJ’s approach to individual accountability...more

Society of Corporate Compliance and Ethics...

Small things with big implications

I recently read about a banker being fired for inflating his expense report to the tune of a sandwich, some pasta, and a coffee. A judge ruled in the bank’s favor in a wrongful dismissal suit filed by the former employee. ...more

A&O Shearman

Top challenges for white collar crime and investigations lawyers in 2024

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We asked our global white collar crime team for their views on the key challenges in 2024 for in‑house investigations teams and white collar crime lawyers, and how to manage the associated risks. Here is what they said. ...more

Davis Wright Tremaine LLP

FINRA’s 2024 Annual Regulatory Oversight Report: Select Observations

FINRA recently published its 90-page 2024 Annual Regulatory Oversight Report (Report) providing member firms with insight into six primary topics: Financial Crimes, Crypto Asset Development, Firm Operations, Communications...more

Ankura

Navigating Uncharted Waters: Challenges and Considerations in Auditing the Ownership of Crypto Assets

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The rapid rise of crypto assets has presented both opportunities and challenges for auditors, with regulators, practitioners, and businesses grappling to establish clear guidelines and procedures. Even though there is no...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cyber Fraud Alleged by Former CIO for Purported Noncompliance With DoD Cyber Requirements

A recently unsealed case against Pennsylvania State University: - Serves as yet another example of the increased use of the False Claims Act (FCA) in cybersecurity enforcement. - Underscores the need for companies...more

ArentFox Schiff

2024 Examination Priorities for Investment Advisers from SEC Division of Examinations

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The US Securities and Exchange Commission (SEC) Division of Examinations recently released its 2024 Examinations Priorities, a yearly report that provides insight into the Division’s areas of focus to improve compliance,...more

StoneTurn

Can Understanding Insider Risk Help to Prevent Fraud?

StoneTurn on

The UK government is moving towards introducing a new corporate criminal offence: Failure to Prevent Fraud and Money Laundering. The draft offence, contained in the Economic Crime and Corporate Transparency Bill, would hold...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - September 2023

Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more

Ankura

Failure to Prevent Fraud: Reasonable Procedures and Preparing Your Organization for the New Offense

Ankura on

An amendment to the Economic Crime and Corporate Transparency Bill (the Bill) has brought in the offense of failure to prevent fraud (Offense). Under the new Offense, an organization will be liable where a specified fraud...more

HaystackID

[Webcast Transcript] M365 for Law Firms and Lawyers: Purview Premium eDiscovery and Security, Capabilities and War Stories

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Editor’s Note: In a rapidly evolving technological landscape, understanding the capabilities and limitations of platforms like Microsoft 365 (M365) is crucial for law firms, especially in the realms of eDiscovery and...more

Lippes Mathias LLP

The Curious World of Inspectors General

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One government agency type that has gathered increasing attention in the last several years is that of the Inspector General. Inspectors General are found at both the federal and state level. Some have broad-based powers...more

Ius Laboris

Who needs an anti-money laundering officer?

Ius Laboris on

Both individuals and companies risk severe penalties if they contribute to money laundering, even if the contribution is the result of negligence. By appointing an anti-money laundering officer organisations will reduce their...more

WilmerHale

Failure to Prevent Fraud for UK Corporates

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The UK Government yesterday introduced a new corporate “failure to prevent fraud” offence into draft legislation, the Economic Crime and Corporate Transparency Bill (“the Bill”). This is a significant development in UK...more

Ankura

Covid-19 and the Public Health Emergency

Ankura on

On October 13, 2022, the Secretary of Health and Human Services (HHS) officially extended the COVID-19 public health emergency (PHE) for another three months, now valid through January 11, 2023. Additionally, HHS has...more

Pillsbury Winthrop Shaw Pittman LLP

Congressional and Government Investigations in 2023: What to Expect from the New Congress

As the 118th Congress prepares to take office, those who may be targets of a new congressional agenda emphasizing government investigations should assess and address their vulnerabilities. Top industry targets for...more

ArentFox Schiff

Customs' New Modernized Broker Regulations Change the Broker-Importer Dynamic: Are You Prepared?

ArentFox Schiff on

On October 18, 2022, US Customs and Border Protection (CBP) published the long anticipated final rule for the modernization of Customs broker regulations under 19 CFR part 111. The rule will go into effect on December 19,...more

Jenner & Block

Government Contracts Legal Round-Up | 2022 Issue 19

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Welcome to Jenner & Block’s Government Contracts Legal Round‑Up, a biweekly update on important government contracts developments. This update offers brief summaries of key developments for government contracts legal,...more

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