Suzanne Folsom on Corporate Compliance Issues -
Presumably at this point HIPAA, HITECH and the Omnibus Regulation have been published, digested and everyone is in full compliance with the requirements that have been set forth....more
The banking world is littered with institutions that have paid astronomical fines for their failures around anti-money laundering (AML) legislation....more
On 31 May 2013, Regulation (EU) No 462/2013 (the “Amendment Regulation”) that further amends Regulation (EC) No 1060/2009 on credit rating agencies was published in the Official Journal. This was accompanied by a short...more
The third batch of subsidiary legislation for the implementation of the new Companies Ordinance was gazetted in May...more
On June 6, the FDIC released a report which discusses the credit risk assessments that banks must now apply to investment portfolios....more
In This Issue: SEC Proposed Rule on Money Market Reforms; FDIC Final Rule on Orderly Liquidity Authority; FDIC Credit Risk Assessment Report; CFTC No-Action Relief; CFPB Exam Procedures for New Mortgage Rules; Rating Agency...more
Several governmental agencies, including the Internal Revenue Service (IRS), Department of Labor (DOL), Securities and Exchange Commission (SEC) and Department of Health and Human Services (HHS), have stepped up their audit...more
On May 7, 2013, the PCAOB reproposed for comment: (1) an auditing standard on related parties; (2) proposed amendments to certain PCAOB auditing standards regarding significant unusual transactions; and (3) other proposed...more
With companies soon facing new enterprise risk and corporate governance requirements, this alert discusses whether companies are prepared for state implementation and outlines new NAIC actions relating to conducting an...more
Yesterday I reviewed the facts surround Total SA’s (Total) lengthy bribery scheme to win contracts in Iran....more
I learned recently some rather extraordinary news: my firm is currently the only mortgage risk management firm in the country offering testing of a Residential Mortgage Lenders and Originator’s (RMLO’s) Anti-Money Laundering...more
As health information technology (HIT) advancements proliferate, so too must governing regulations. Three agencies – the Food and Drug Administration (FDA), the Office of the National Coordinator for Health Information...more
The front page of the Monday, June 3, 2013, Wall Street Journal featured the headline, “Risk-Averse Culture Infects U.S. Workers, Entrepreneurs.” The story explores the question of whether our collective fear of risk is...more
Program and culture assessments - Assessments have long been recognized as having a critical impact on the effectiveness of ethics and compliance efforts. Best practice programs have often employed assessments – formal...more
In the last 10 years, the Equator Principles or EPs have emerged as the industry standard for financial institutions to assess social and environmental risk in the project finance market. The EPs — which are based on the...more
Today we celebrate that noted British comedian who made his fame in America – Bob Hope. ...more
Can you synthesize and reconcile the world’s leading laws, regulations and commentaries on the best practices an anti-bribery and anti-corruption compliance program. ...more
The Environmental Protection Agency (EPA) is responsible for registering pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). ...more
Introduction - Investing in the health care industry can be riskier and more complicated than investing in many other industries. Health care providers and suppliers, as well as those companies that interact with them,...more
On May 7, 2013, the U.S. Equal Employment Opportunity Commission ("EEOC") reached a milestone of sorts as it filed – and then settled – its first complaint ever alleging genetic discrimination under the Genetic Information...more
Potential buyers and sellers take note — on April 16, 2013, the U.S. Environmental Protection Agency (U.S. EPA) issued draft guidance that would require more evaluation of "vapor intrusion" (migration of any hazardous vapors...more
U.S. importers that are members of the Customs-Trade Partnership against Terrorism (C-TPAT), when serving as U.S. exporters of goods to the European Union (EU), will receive expedited Custom clearance, decreased inspection...more
The King & Spalding Energy Forum on Crisis Management took place in Houston on March 28, 2013, and was broadcast live via webinar. Tracie Renfroe, a partner at King & Spalding’s Houston office, moderated the panel discussion...more
Introduction - The knock-on effects of the global economic crisis have influenced the financing of the commodities trading industry. Changes in the regulatory landscape in Europe and the United States have likewise...more
The bottom-line: If you do not conduct a risk assessment, then you should start praying. The FCPA Guidance made it clear – conduct a risk assessment and tailor your compliance program to the risk assessment....more
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