Internal Audit Functions

News & Analysis as of

White Collar Enforcement and the New Trump Administration: Your Top Ten Questions Answered

Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more

When It Comes to Documentation, Smart Companies Behave Like Every Day Is Audit Day

Audits are part of nearly every ethics and compliance program. They come from the Internal Audit Department, outside auditors testing control systems and processes, and in some cases, government regulators evaluating the...more

Insight from CFPB Regarding Employee Incentives in the Wake of Wells Fargo Consent Order

This past November, in the wake of the Wells Fargo debacle, the CFPB issued a Compliance Bulletin which addressed employee incentives and the consumer risks associated with them. CFPB Compliance Bulletins are non-binding...more

Compliance Trends and Predictions for 2017

The past year was another great success for the compliance profession and related technologies. Compliance continues to grow as the “professionalization” of compliance continues to skyrocket. As my good friend Donna Boehme...more

Do Not Repeat the Mistakes of Your Diva

Preparation pays off. While it may be well known that “practice practice practice” gets you to Carnegie Hall, it appears you don’t even need to do the sound check to play Times Square on New Year’s Eve. Mariah Carey’s...more

How to Prepare for New Equal Pay Requirements

The Equal Pay Act in the United States dates back to the early 1960s. But its enforcement—and the conversation about equal pay issues around the globe—requires close watching in the next few years....more

Private Right of Action under CASL coming July 2017

Canada’s Anti-Spam Law came into force on July 1, 2014. Since then, all eyes have been on the Canadian Radio-television and Telecommunications Commission (CRTC) for decisions concerning CASL violations. In the cases made...more

Federal Minimum Salary Increases for Exempt Workers Take Effect December 1, 2016

If you have not audited your exempt employee pay practices for compliance with the federal Department of Labor’s rules announced earlier this year, you have just under two weeks to do so. Starting December 1, 2016, the...more

5 Key Takeaways from AB InBev SEC FCPA Settlement

The Justice Department and the SEC have been busy over the last 2 weeks in the FCPA arena. For those who have raised doubts about DOJ and the SEC’s continuing commitment to FCPA enforcement, you should forever hold your...more

Electronic Discovery Preparedness Audit Handbook

While your organization may not regularly be involved in costly or complicated litigation, there are instances in which it may nonetheless be required to identify, collect, and produce documents most likely in the form of...more

Resource for Companies Evaluating Compliance with New Overtime Laws

Many companies are in the process of completing internal audits to prepare for the new salary and overtime rules that go into effect on December 1, 2016. While the changes do not impact the duties-portion of FLSA exemptions,...more

U.S. Employers Facing Increased Fines for Form I-9 Violations

The U.S. Department of Justice recently announced significant increases in fines for immigration-related paperwork violations, in an interim final rule slated to take effect this fall. Harsher financial penalties come as part...more

Convergence of Audit and Compliance Functions

Returning to the serious subject of compliance, there are some who argue that compliance is a lot simpler than professionals and commentators tend to describe. I am an advocate for simplicity as a way to ensure adoption of...more

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

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

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