Internal Audit Functions

News & Analysis as of

Getting Back to Basics: CCOs and Independence

Chief compliance officers continue to enjoy these heady days – salaries are up and new opportunities are popping up in the corporate world. CCOs have to keep their eye on the ball. It is well and good to get a good salary, a...more

UK Financial Regulatory Developments - February 2016 #6

OBWG publishes open banking standard - The OBWG, set up at Treasury’s request, has set out an Open Banking Standard to guide how open banking data should be created, shared and used by its owners and those who access it....more

Rubik’s Cube and the Intersections of Compliance

It is generally believed that the world’s single best selling toy is the Rubik’s Cube, invented in 1974 by the Hungarian Erno Rubik. Although it was initially believed that Rubik’s Cube was built as a teaching tool to help...more

Proposed Regulations Adopting NAIC’s Internal Audit Function Requirements Announced

Large insurers should be preparing now to comply with proposed regulations that adopt the NAIC’s internal audit function requirements. The internal audit function is designed to provide independent, objective and reasonable...more

Blog: UK’s PRA publishes Questions & Answers on the Senior Insurance Managers Regime

The UK’s PRA has published a set of Q&As on the Senior Insurance Managers Regime that are well worth reading if you outsource your internal audit or actuarial functions, and you’re still struggling to make sense of the rules...more

PRA updates on credit unions’ use of third parties

PRA has updated its webpage on PRA’s supervision of credit unions by clarifying its expectations for credit unions using third parties for internal audit services. PRA takes the view that, where appropriate, the use of third...more

Government Offers Guidance for Employers Conducting Internal I-9 Audits

The U.S. Immigration and Customs Enforcement (ICE) Office of Special Counsel for Immigration-Related Unfair Employment Practices recently issued guidance to help employers conduct internal I-9 audits in compliance with the...more

Claims Management Company Discloses Possible FCPA Violations

On November 9, an Atlanta-based claims management firm, disclosed that it had reported possible FCPA violations to DOJ and SEC. The company discovered the possible violations during an internal audit and has since launched an...more

Building a Due Diligence Infrastructure (Part IV of IV)

A due diligence infrastructure is designed to demonstrate a company’s good faith commitment to compliance with anti-corruption laws by: identifying corruption risks; and mitigating such risks to ensure that the company does...more

Capturing The SEC

Suppose you are selling a service with some success.  You want to increase sales, but how?  You could promote the value of your services, but some may disagree and others may be indifferent.  A more certain solution would be...more

Cleaning Up a Compliance Program Mess

You have just been hired as the new Chief Compliance Officer of a global company operating in over 80 countries, including numerous high-risk corruption countries. You have no staff and have been given a budget to hire 5...more

FCA and Ofgem Question Adequacy of Commodity Firms’ Compliance and Market Abuse Controls

In the most recent edition of its regular market conduct and transaction reporting-focused ‘Market Watch’ publication, the UK Financial Conduct Authority (“FCA”) provides a review of commodities firms’ compliance and...more

The Necessary Ingredient to Compliance Success: Interpersonal Skills

We always bandy the phrase around of “people skills,” or the old trendy phrase of “emotional intelligence.” Hopefully, this posting can create some ideas around new approaches to these old concepts and trendy terminology....more

The Health Law Guide to Hospital Operations

This operations guide provides a brief look at health law issues hospitals deal with on a daily basis. While a detailed coverage of the elements, drafting, implementation and continued governance of a hospital compliance...more

An HR Challenge: Finding and Fixing Overtime Misclassifications in 4 Steps

In light of the United States Department of Labor’s (“DOL”) June 30, 2015 report and proposed amendments to the salary portion of the ‘white collar’ exemptions that would more than double the minimum salary of those exempt...more

Ethics & Compliance Training Best Practice FAQs: Top Five Questions from the Training Benchmark Webinar Answered

During our recent webinar (now available on-demand), we provided an in-depth tour through the findings of our 2015 Ethics & Compliance Training Benchmark Report. Webinar attendees asked a number of valuable questions on...more

Great Structures Week III – The Roman Arch and Resourcing Your Compliance Program

I continue my Great Structures Week with focus on structural engineering innovations from ancient Rome. I am drawing these posts from The Teaching Company course, entitled “Understanding the World’s Greatest Structures:...more

SEC Issues Concept Release Requesting Input on Potential Audit Committee Disclosure Requirements

At an open meeting held on July 1, 2015, the Securities and Exchange Commission (SEC) issued a concept release seeking input on whether it should adopt rules requiring additional disclosures for audit committees, with a focus...more

OIG Releases New Compliance Oversight Guidance for Health Care Governing Boards

On April 20, 2015, the U.S. Department of Health and Human Services Office of Inspector General (OIG), in conjunction with the American Health Lawyers Association (AHLA), the Association of Healthcare Internal Auditors (AHIA)...more

Monthly Benefits Alert - May 2015

As we do every month, we have provided below a comprehensive alert that highlights the most important employee benefits legal developments during May of 2015. We hope that our “Monthly Benefits Updates” continue to be a...more

Risk Assessment: A Natural Partnership for Internal Auditors and CCOs

In the corporate compliance world, chief compliance officers and internal auditors are natural allies. They often report to the same board committee, share a common perspective on corporate operations, and are aimed at...more

OIG Releases Compliance Guidance for Health Care Governing Boards

The Office of Inspector General (“OIG”) of the U.S. Department of Health and Human Services (“DHHS”) released new compliance guidance for health care governing boards, attorneys, compliance officers and internal auditors on...more

SEC Awards Million-Dollar Whistleblower Bounty To Compliance Professional

Last week, the U.S. Securities and Exchange Commission ("Commission" or "SEC") issued an order awarding as much as $1.6 million to a "compliance officer" for information that helped the Commission resolve an enforcement...more

HHS OIG Issues Guidance to Healthcare Boards Regarding Oversight

On April 20, 2015, the United States Department of Health and Human Services Office of the Inspector General (OIG) issued guidance aimed at the governing boards of healthcare entities. The guidance—issued in conjunction with...more

SEC Awards Compliance Officer Whistleblower Bounty of Approximately $1.5 Million

Wednesday, the SEC announced that it would pay an unidentified compliance officer a whistleblower bounty award of between $1.4 and $1.6 million. This is the second award that the SEC has made to a whistleblower with internal...more

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