Risk Assessment Compliance

News & Analysis as of

Win-Wins: Looking for Business and Compliance Success

A Chief Compliance Officer who lacks working relationships with the business side of a company is like a day without sunshine. No matter how strong or finely tuned a compliance program is on paper – in practice, the success...more

How Can I Make Sure My Compliance Training Program Covers All My Risks?

Building a compliance training program that covers all of your organization’s risks isn’t easy. To do it in a way that ensures you cover your bases without creating training fatigue means creating a multiyear training...more

Australia Implementing Reforms to the National Industrial Chemicals Notification and Assessment Scheme (NICNAS)

As most recently reported in our October 28, 2015, Global Regulatory Update, the Australian government is implementing reforms to the National Industrial Chemicals Notification and Assessment Scheme (NICNAS). According to an...more

Adequate Procedures—The Current State of Play

The legal concept of “adequate procedures” was introduced in the UK Bribery Act in 2010 as a defence to the corporate offence of failing to prevent bribery. That said, the concept itself has in fact been present in corporate...more

Compliance Counsel Metrics-Part I, Board and Senior Management Roles

We begin our exploration of the new Department of Justice (DOJ) Compliance Counsel and the metrics laid out by Assistant Attorney General Leslie called for her review of compliance programs. Today we review the first criteria...more

Australian Anti-Bribery & Compliance Trends

Today we welcome Ted Williams, Partner, Piper Alderman. Ted, can you share some of your background and experience? TW: Thank you, Richard, for the opportunity to engage with your community, and it was a pleasure to...more

Anti-Corruption: Why Programs Fail

Today, companies around the world face daily challenges associated with corruption. This risk coupled with new laws and heightened enforcement are just a few of the factors driving companies to implement and improve...more

Layla and Other Love Songs and Risk Assessments

On this date in October 1971, Duane Allman died. He was the co-founder, along with his brother Greg, of the Allman Brothers Band. For my money he was one of the greatest guitarists of all time. At the time of his death, the...more

Are You Overcomplicating Your Cybersecurity Processes?

Yes. I just asked that. For many, the response is likely “Yes! Of course we are! It’s *&^%$% cybersecurity – it’s complicated!” To which I would respond “Touché. It is…but it needn’t be overly complicated.” So, of...more

Tips for Going Global: Plan Before You Expand

Companies enjoying success in the U.S. often seek global expansion to gain strategic benefits from accessing new markets—new revenue potential, talent acquisition and increased brand awareness. Before replicating your...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

Fantasy Sports Scandal Shows Importance of E&C Programs for Growing Companies

A recent scandal rocking the daily sports fantasy industry is another example that shows why companies—particularly young, growing companies—need ethics and compliance programs. Without them, it’s a good bet problems will...more

U.S. SEC Proposes Liquidity Risk Management Programs, Optional “Swing Pricing,” and Liquidity Reporting for Mutual Funds and...

On September 22, 2015, the Securities and Exchange Commission (“SEC”) proposed a new rule and amendments to rules and reporting forms under the Investment Company Act of 1940 (the “1940 Act”), designed to standardize...more

Interview: Amy Much - Director, Global Compliance, Under Armour

Protect This House - Amy Much discusses building a compliance program from the ground up at a fast moving, international organization....more

Dissecting a Bribery Violation: Two Important Questions to Answer

In the wreckage of a corporate FCPA enforcement action, a company has to answer two important questions. First, how did the conduct occur without senior executives and the Board learning or suspecting that such conduct...more

Meaningful Use Audits: Proactive Tips for Success

For health care professionals who began accepting Meaningful Use incentive money at the outset of availability under the Medicare option in 2011, the year 2015 is an important year. If the provider has met all core...more

New Study Highlights Anti-Bribery & Corruption Gaps & Risks

Everyone reading this post should have conducted a corporate risk assessment (CRA) in the past couple years. If not, stop reading and go conduct one now. Seriously, how can you know if your compliance program resources,...more

Failing to prevent bribery – prevention is better than cure

On 25 September 2015, the Civil Recovery Unit in Scotland recovered £212,800 from Brand-Rex Limited ("Brand-Rex") under an agreed civil settlement, after Brand-Rex self-reported the fact that it had benefited from unlawful...more

Astros in the Playoffs, Will Hell Freeze Over?

When recently I contacted the Underworld about the potential listing of this vast property, I was stunned when Satan himself answered the phone. While I was tempted to ask what happened to all his hired help down there,...more

Making Compliance Easier and Smarter Through Technology: Intuitive Interface and Intelligent Data Gathering is Helping WorldRemit...

WorldRemit is an online money transfer service. It’s bringing a strong challenge to other players in this field through easier-to-use services and lower fees. But while it may be an innovative company, it is still challenged...more

How Can the Automotive Industry Strengthen Its Regulatory Compliance Process and Reduce Its Compliance Risks?

Many Americans listened last week to the admissions by the now former President of Volkswagen that the company had been “dishonest” and had cheated on the U.S. emissions tests. How was this happening at the world’s #1...more

Companies: Five Steps to Protecting Trade Secrets

If your management team knows it needs to better protect company trade secrets but isn’t sure where to start, take note. CREATe.org and PwC have put together a five-step framework to guide companies on how to identify, assess...more

SEC’s Increased Cybersecurity Enforcement and How to Reduce Your Risks

The SEC announced last week that an investment adviser had agreed to settle charges that it failed to take required steps to protect against and respond effectively to a cybersecurity breach. The action comes on the heels of...more

The SEC OCIE Announces Increased Scrutiny of Broker-Dealers’ and Investment Advisers’ Cybersecurity Programs

On September 15, 2015, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a National Exam Program Risk Alert (2015 Risk Alert) to provide broker-dealers and investment...more

TN Ethics Opinion Approves Lawyers’ Cloud Storage of Client Data

Tennessee has joined other states in formally approving lawyers’ cloud-storage of client-confidential data. The Board of Professional Responsibility (“BOPR”) held that lawyers ethically may use cloud storage for...more

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