News & Analysis as of

Compliance is No Joke: OCR Releases Security Risk Assessment Tool

On March 28, 2014, the Office of Civil Rights (OCR) announced the release of an online and iPad app-based security risk assessment (SRA) tool. The tool is intended to help health care providers in small to medium sized...more

The Ides Of March And Evaluation Of Compliance Risk

Tomorrow, March 15 is enshrined as one of the most famous days of all-time, the “Ides of March”. On this day in 44 BC, the “Dictator for Life” Julius Caesar was assassinated by a group of Roman nobleman who did not want...more

The Importance Of A Risk Assessment

Sometimes people operate with blinders. I don’t mean to suggest that people deliberately put blinders on to ignore issues – they sort of just grow into a person’s personality....more

For FCPA Compliance, Tone At The Top Key, Lack of Policies A Difficulty

The number of FCPA enforcement actions brought in recent years has declined. The SEC, for example, reports that in fiscal 2013 it brought 8 cases, compared to 10 in 2012 and 15 in 2011. Nevertheless, those who might be...more

More Lessons From Workplace Safety For The Compliance Practitioner

I have long believed that the compliance discipline has quite a bit to learn from the area of safety in the workplace. This is not only because I believe that the changes in corporate attitudes about safety presage many of...more

A New Approach To Compliance: “Informed” Risk And Resource Allocation

The compliance field has had an incredible five years. From backwater offices and responsibilities, CCOs are now taking a seat at senior management tables to provide important risk-based assessments and policies to enhance...more

Key Provisions of the Volcker Rule Final Regulations for Non-US Banking Entities

The five US financial agencies (“Agencies”) have approved jointly prepared final regulations (“Final Rules”) to implement the prohibitions on engaging in proprietary trading and investment in or sponsorship of a private...more

Summary of the Volcker Rule

On December 10, 2013, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission, and the Commodity...more

Honor Our Veterans And Compliance In The Supply Chain

Today is National Remembrance Day for Veterans who served their country and across the world. In the US we call it Veterans Day....more

A Prescriptive Guide To Third Party Risk Management

The recent examples of compliance program credits for Morgan Stanley and Ralph Lauren have demonstrated that, more than ever, an effective compliance program can protect a company from criminal indictment and generate bottom...more

Drilling Down On Due Diligence: Raising The Bar

I am sure Justice Department and Securities and Exchange Commission lawyers sometimes sit back and marvel at the world they have helped create – Companies are devoting more resources to the due diligence process for screening...more

Einstein’s Theory Of Relativity And Compliance

I am always surprised at creative links between compliance principles and major historical events and concepts....more

SEC Announces Three New Enforcement Initiatives

On July 2, 2013, the SEC announced the creation of the Financial Reporting and Audit Task Force, the Microcap Task Force and the Center for Risk and Quantitative Analytics with the goal of combating fraudulent financial...more

Operational Regulatory Risks Facing Private Equity Firms

If you work in the private equity world, you probably know that you are already exposed to a variety of regulatory risks and obligations that can have a significant impact on your firm’s operations and financial rate of...more

Three’s Company, Too: The SEC’s New Enforcement Initiatives Will Be Waiting For You

Last week the SEC announced the creation of three new Division of Enforcement initiatives designed to combat fraud in financial reporting and microcap securities and to enhance risk identification and analysis: (1) The...more

Anti-Corruption Compliance Program Assessments

Forgive me for dedicating a posting to this topic, since I have a vested interest in this topic. I have conducted a number of Anti-Corruption Compliance Program Assessments....more

Corporate Review June 2013 - Changes to Impact U.S. and Canadian Public Companies Using COSO Internal Control Framework

The Sarbanes-Oxley Act of 2002 requires companies that are subject to U.S. reporting requirements to establish and maintain a system of internal control over financial reporting and periodically assess the effectiveness of...more

Employment Law Blog: Regzilla Stomps Another One! - Idaho State University and the Compliance Gap Analysis

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

How To Assess Suspicious Financial Activity

The banking world is littered with institutions that have paid astronomical fines for their failures around anti-money laundering (AML) legislation....more

Corporate Governance Insights - Issue 2

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

Return To The Baker’s Dozen In A Best Practices Compliance Program – Total Part II

Yesterday I reviewed the facts surround Total SA’s (Total) lengthy bribery scheme to win contracts in Iran....more

Our Approach to Risk Assessment

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

Risk Assessments In An Anti-Money Laundering Compliance Program

Today we celebrate that noted British comedian who made his fame in America – Bob Hope. ...more

What Are The Essential Elements Of A Corporate Compliance Program?

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

Practical Suggestions For Conducting Risk Assessments

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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