It's important for employees to follow company policy, but it's even more important for employers to have those policies in the first place. In this case, the Fifth Circuit dealt a harsh blow to an employee who complained,...more
What’s an employer to do when a disabled employee has repeated opportunities to ask for an accommodation but doesn’t act on them? In a recent case, a federal court in Texas ruled that the employer was justifiable in...more
By every indication we are about to witness a dramatic leap in technology-enabled ethics and compliance.
Tech Advancement in Key E&C Areas -
Trends and our own client experiences are demonstrating that we are...more
As of early December 2014, 1,170 security breaches under the Health Insurance Portability and Accountability Act (HIPAA) involving 31 million records had been reported to the U.S. Department of Health and Human Services (HHS)...more
The SEC named ratings giant Standard & Poor’s in three actions this week and one of its senior executives in another. The firm settled all three actions, admitting to a series of facts but not violations of the law in one...more
Cybersecurity again looks to feature prominently on 2015’s regulatory agenda. So far this year, the Financial Industry Regulatory Authority and the SEC’s Office of Compliance Inspections and Examinations (OCIE) have announced...more
Michigan governmental entities will face significant new regulations on how they charge for responses to Freedom of Information Act (FOIA) requests beginning July 1, 2015.
Maryland nursing homes must submit their policies and procedures for resident access to and requests for medical records to the Maryland Department of Health and Mental Hygiene's Office of Health Care Quality (OHCQ) by...more
On December 29, 2014, final regulations were released under Internal Revenue Code section 501(r). Enacted as part of the Patient Protection and Affordable Care Act in 2010 (the “ACA”), section 501(r) requires tax-exempt...more
The Office of Inspector General’s (OIG) work plan, updated as of November 7, 2014, indicates that the OIG’s ongoing projects include audits of the CFPB’s information security program, pay and compensation program,...more
NAVEX Global recently hosted a three-part webinar series on how to take a step-by-step approach to rethinking, implementing and overseeing your policy management life cycle.
Webinar attendees asked a number of valuable...more
More and more community banks feel the increasing pressures of growing regulatory compliance requirements. To meet those requirements, many banks are turning to creative solutions, ranging from outsourcing compliance...more
Rapidly changing circumstances raise workplace questions.
The Ebola epidemic in 2014 has already been confirmed by the U.S. Centers for Disease Control (CDC) as the worst in history. The extent of this outbreak is...more
The Office of the Comptroller of the Currency (OCC) on October 30 published revised policy and procedures for how it manages Matters Requiring Attention (MRAs) resulting from its examination of supervised institutions. MRAs...more
Companies in every industry—private and public—struggle with the difficult task of promptly identifying employee wrongdoing and responding appropriately. The National Football League continues to be embroiled in a controversy...more
Now more than ever, it is important to understand brand standards: why they are set; how they affect franchisors, franchisees, and customers; and what the boundaries of brand enforcement policies should be....more
Registered investment advisers are required to review their policies and procedures on at least an annual basis. As aid to the required review, below is a summary of material developments during the past...more
The Securities and Exchange Commission for the first time brought charges against a broker-dealer for failure to adequately protect against insider trading by its employees. The charges stem from a broker’s use of a...more
In light of these new realities corporations face, the first step a company should take is to establish internal guidelines addressing interaction with government agents. Companies should have a response policy in place and...more
On August 14, Freddie Mac issued Bulletin 2014-15, which reminds seller/servicers subject to the AML requirements of the BSA that they are expected to maintain an AML compliance program and are required to report to Freddie...more
The Office of the Inspector General (OIG) for the U.S. Department of Health and Human Services released a report and recommendations for nursing facilities to develop and implement written policies related to reporting...more
It is ironic to learn the Office of Inspector General (OIG) believes the Office of the National Coordinator for Health Information Technology (ONC) essentially has an insufficient compliance program to maintain the privacy...more
Anti-corruption, anti-bribery, anti-money laundering (AML) programs policies and procedures and even export control systems are seemingly in a constant state of evolution. Many companies are struggling with the challenge of...more
So, now you’re ready to start your culture audit… Some key questions you want to ask before you start are:
Do I have the support of Executive leadership? If not, go back to your E&C steering committee and work through...more
We’ve talked a lot in our Tales from the Crypt about the signs to watch for that indicate something’s gone wrong, from minor cultural twists to lapses of integrity that are tantamount to criminal activity. We all wish we had...more
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