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Risk Assessment

OIG Work Plan – October 2017 Update

by Baker Ober Health Law on

The OIG added five new items to its Work Plan with its October 2017 monthly update. This is a decrease from the nine new items added to the Work Plan with the September 2017 update. (For more information on last month's Work...more

SCCE Wrap Up – Final Reflections on CEI 2017

by Thomas Fox on

The 2017 SCCE Compliance and Ethics Institute (CEI) is now in the books. Once again, the organization had record setting attendance with over 1,800 attendees from some 41 different countries. During the event, I had the...more

Pros and Cons of Hiring a Security Rating Agency

by Patrick Law Group, LLC on

One can hardly check out any news outlet today without reading or hearing about a security breach. Experts frequently advocate performing internal assessments to identify security weaknesses. Commentators tout the...more

ISO 37001: Risk Assessments, Employees, and Due Diligence Requirements (Part IV of V)

by Michael Volkov on

In Part IV of my series on ISO 37001, I examine requirements relating to risk assessments, design of policies and procedures, and due diligence requirements. Section 4.5 sets out requirements for conducting risk...more

What a CEO Needs to Hear to Invest More in Compliance – Strategy

by NAVEX Global on

Does your organization invest in compliance, or just pay for it? This is not a rhetorical question. There’s a big difference between merely covering the expense of a program and investing in it. Investment decisions are...more

Financial Services Quarterly Report - Third Quarter 2017: Global Update: UK Criminal Finance Act 2017: Immediate Considerations...

by Dechert LLP on

UK asset managers, non-UK asset managers carrying on business in the UK and the funds they manage are within the scope of the new corporate criminal offences of failing to prevent the facilitation of tax evasion. As the new...more

The Mummy’s Hand and a Risk-Based Approach at the Board Level

by Thomas Fox on

Today we consider the 1940’s film, The Mummy’s Hand as the second installment in Universal Pictures series featuring this creature. Boris Karloff departed the role and it was taken over for one film by Tom Tyler, who was...more

Breaking Down the 2017 DOJ and OIG Compliance Guides

by McDermott Will & Emery on

Earlier this year, DOJ and OIG independently issued guides focused on evaluating compliance program effectiveness. The guides approach the topic from different perspectives but cover overlapping themes and work well in...more

Turning Passive Detection into Active Incident Management

by NAVEX Global on

Effective incident management programs do not just exist, they are celebrated. The best programs achieve this by operationalizing their incident management programs into their organization’s DNA. This turns passive reporting...more

An Assessment and Comparison of New TSCA and REACH

by Jones Day on

Passage of the Frank R. Lautenberg Chemical Safety for the 21st Century Act, or "New Toxic Substances Control Act," introduces a number of changes to regulations for the collection and assessment of information concerning...more

The Importance of A Robust Conflicts of Interest Program

by Michael Volkov on

It is always interesting to learn how companies handle specific compliance issues. Years ago, I could always tell when a compliance department was lacking in stature and independence in a company. Typically, I observed three...more

DoD Issues Guidance for Compliance with Cybersecurity Regulations

by Holland & Knight LLP on

• In recently released guidance, the U.S. Department of Defense (DoD) confirms a "one size does not fit all" approach to contractor compliance with its cybersecurity clauses that cover the safeguarding of contractor networks,...more

OCIE Lessons From Cybersecurity 2 Initiative

by Carlton Fields on

On August 7, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert containing observations from its Cybersecurity 2 Exam Initiative. As a follow-up to the 2014 Cybersecurity 1 initiative, the...more

The Importance of Creditworthiness and Risk Assessments

by Locke Lord LLP on

The FCA consultation distinguishes between two main areas of risk when assessing consumer credit: These are credit risk and affordability risk. The FCA has launched a recent consultation to clarify the rules on assessing...more

ECHA Announces RAC Concludes on Opinion for Harmonized Classification and Labeling for Titanium Dioxide

by Bergeson & Campbell, P.C. on

The European Chemicals Agency (ECHA) announced on September 27, 2017, that the Committee for Risk Assessment (RAC) concluded on ten opinions for harmonized classification and labeling (CLH), including titanium dioxide. In...more

The Data Report Episode 14: Zero Day

by Bilzin Sumberg on

Module Four: When It All Goes Wrong (Part III) Once a data breach is discovered there is a limited amount of time to begin assessing, addressing, and eliminating the problem. In this episode of The Data Report, Litigation...more

Financial Regulatory Observer - September 2017: Cybersecurity: Regulators show their teeth

by White & Case LLP on

New formal cybersecurity standards covering US financial institutions could have ramifications that reach far beyond New York. US regulators usually issue cybersecurity guidance instead of regulator standards and...more

OIG Work Plan – September 2017 Update

by Baker Ober Health Law on

Beginning in June 2017, the OIG began making monthly Work Plan updates. These monthly updates create some practical challenges for health care providers and compliance professionals trying to make operational and compliance...more

Risky Business: Mitigating Exposure Through Comprehensive Risk Management

by Ropes & Gray LLP on

Ropes & Gray is pleased to share “Risky Business,” a comprehensive report on trends and best practices in risk management. Based on a survey by FT Remark, a research service from the Financial Times that interviewed 300...more

Financial Regulatory Observer - September 2017: Calculation of risk-weighted credit exposures

by White & Case LLP on

Regulators are trying to bring consistency in calculating risk-weighted assets, casting further doubt on the use of internal models by financial institutions. The Capital Requirements Regulation (CRR) requires credit...more

Moving Back In-House to Move Compliance to the Next Generation

The following interview is with Nicole Rose, Head of Risk and Compliance, Uniting Resources NSW and ACT. As you may recall, Nicole and I co-produced the anti-bribery training animation, “Why We Say Yes,”. RB: So, Nicole, I...more

Insurance Broker Series: Gardner Jones, ABD Insurance and Financial Services

Farella’s Insurance Recovery Group lawyers regularly collaborate with and learn from different players and functions within the insurance industry. To provide more value to our readers, we have reached out to a series of...more

A Legal and Commercial Checklist for Bankable Solar EPC Contracts: A Developer’s Guide

Large-scale solar development is big business, and solar EPC Contracts are big business by association. In Q2 2017, the U.S. solar market installed 2,387 MWdc, an 8% increase year-over-year, and the largest second quarter...more

A Category 5 Compliance Problem: Hurricane Irma Gives Providers a Stark Reminder of Emergency Preparedness Realities

by Carlton Fields on

The havoc that Hurricane Irma caused in the Caribbean and most of Florida reminds us of the Centers for Medicare and Medicaid Services (CMS) requirements for emergency preparedness, which take effect November 15....more

New York’s Cybersecurity Requirements Pose Multi-Year Compliance Challenges

by McDermott Will & Emery on

New cybersecurity regulations issued by the NYDFS define the nonpublic information they regulate in exceptionally broad terms. This expanded definition of Nonpublic Information will create major challenges for regulated...more

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