News & Analysis as of

Risk Assessment Compliance

AML/CTF - A decade’s experience

by Dentons on

As the AML/CTF regime approaches its 10th birthday, what are the key issues for the finance industry? From 12 December 2007 reporting entities are required to have in place an AML/CTF program documenting how they...more

Holmes, the Fog of London and Root Cause Analysis

by Thomas Fox on

My heart and thoughts continue to go out to my fellow Houstonians, fellow Texans and now Louisianans and all other affected by Hurricane Harvey. I continue my exploration of weather related themes from which the compliance...more

Focusing Antitrust Compliance Programs on the Real Criminal Risks (Part II of II)

by Michael Volkov on

As chief compliance officers realize the importance of criminal antitrust compliance, it is important to identify the real risk factors. All too often we get lost in the mumbo-jumbo (a technical term, I know) of compliance,...more

Across the Board-Episode 5, Visualization of Data for a Board

by Thomas Fox on

In this episode, I visit with Joe Oringel, co-founder of Visual Risk IQ, a data-analytics and visualization company. They have developed a manner to not only extract data but present it in a way that is very interesting, very...more

Day 15 of One Month to More Effective Continuous Improvement-Risk Based Monitoring for Continuous Improvement

by Thomas Fox on

Another mechanism for continuous improvement of your compliance program is through risk-based monitoring. Under Prong 5 of the DOJ’s Evaluation of Corporate Compliance Programs, is the following topic and question: Manifested...more

Using a Human Rights Lens to Strengthen Your Anti-Corruption Compliance Program

Companies are increasingly expected to manage the human rights impacts of their activities. This expectation is embedded in new legislative requirements, in the requirements of business partners and investors, and in the...more

Reflections on My Interview with Hui Chen on Compliance Program Effectiveness

by NAVEX Global on

Hui Chen left her job as in-house compliance counsel for the Justice Department at the end of June, and I had the good fortune to be the first person to interview her post-departure....more

OIG Unveils New Work Plan Process: Assessing the Impact on Compliance Risk Assessment

by Baker Ober Health Law on

On June and July 17, 2017, the Department of Health and Human Services, Office of Inspector General (OIG) released new Work Plan initiatives and, in doing so, announced its intent to update its Work Plan monthly, in lieu of a...more

Chris Froome Wins Tour Again; Maintenance and Compliance

by Thomas Fox on

Just as he did in 2013, in 2015 and in 2016, Kenyan-born British cycling star Chris Froome crossed the finish line in Paris wearing the Yellow Jersey as this year’s winner of the Tour de France. As reported by Chris Chavez,...more

Is Your Company At-Risk for a Government Enforcement Action?

by Michael Volkov on

For some reason, I have always believed that picking successful stocks should not be very difficult. Unfortunately, my record in the stock market does not back up my self-assessment. On the other hand, when it comes to...more

Astros Lead MLB – What is Your Risk Management Process?

by Thomas Fox on

Today’s lesson from the world of sports informs our discussion of compliance and the risk management process; consisting of forecasting, risk assessment and risk management. By starting with forecasting, a compliance function...more

Working in a “Happy Talk” Corporate Culture

by Michael Volkov on

Honesty is the best policy – when there is money in it. – Mark Twain - Compliance professionals encounter a diverse range of corporate personalities in their work. To be sure, compliance officers have to rely on their...more

Are Risk Assessments Just a Report on the Obvious?

by Michael Volkov on

If you give a Chief Compliance Officer truth serum and ask him/her whether they believe a risk assessment is valuable, what do you think the CCO say? Let’s start with the cynical side – not that I am a pessimist. Many CCOs...more

Arbitration Bribery Corruption and Disputes - it's not as easy as ABCD

by Hogan Lovells on

Foreign Corrupt Practices Act ("FCPA") - For energy, mining, and resources companies, the cost of corruption—and getting caught—is real. Less than two months ago, Odebrecht S.A. was ordered by a U.S. federal judge to pay a...more

The EU’s New General Data Privacy Regulation (GDPR) – Global Companies New Compliance Test

by Michael Volkov on

Global companies face a daunting array of risks – anti-corruption, trade compliance, antitrust, and money laundering are just a few. The European Union, however, has escalated the data privacy issue right into the corporate...more

Compliance into the Weeds-Episode 41, Reality Winner and Internal Controls

by Thomas Fox on

In this episode, Matt Kelly and I take a deep dive into the weeds around the story of Reality Winner, the leaking of the NSA report of Russian hacking of the US Presidential campaign and election. We tie it to internal...more

HCCA-OIG Resource Guide on Measuring Compliance Program Effectiveness

by Michael Volkov on

The Health and Human Services Office of Inspector General (OIG) and the Health Care Compliance Association (HCCA) jointly released a resource guide on measuring the effectiveness of a health care organization’s compliance...more

Goodbye to the Midnight Rider and the HR Gap Analysis

by Thomas Fox on

How can you determine if Human Resources (HR) can meet the needs of a best practices compliance program? One place to start is with a gap analysis to determine what HR has in place that can facilitate your company’s...more

Operationalizing Compliance: Part III – Human Resources

by Thomas Fox on

This week I am engaging in a week-long series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I am...more

The State of Mind of a White Collar Criminal

by Michael Volkov on

As a chief compliance officer, it is important to consider the mindset of a criminal. Not to complete tasks and accomplish your objectives. Instead, it is important to understand the criminal mind, what makes them tick and...more

Department Of Justice “DOJ” Issues Evaluation Of Corporate Compliance Programs

by Locke Lord LLP on

Since DOJ hired Hui Chen, its corporate compliance expert, in November 2015, rumors have circulated that DOJ intended to release a list of questions to ask every company that comes into DOJ to explain the effectiveness of its...more

AI for Risk Management in Compliance – A New Business Advantage

by Thomas Fox on

There have been some articles recently which discussed the revolution of technology into compliance, specifically with the introduction of Artificial Intelligence (AI) into the profession. A few pieces claimed this was...more

Real Answers to Common Questions on Cybersecurity

by NAVEX Global on

Q: In my company, the IT directors see cybersecurity as an IT and software issue to be solved with software and hardware. How do I convince the team that employees need to also be trained on risky behavior – something that...more

The Risk Management Process in Compliance

by Thomas Fox on

An exploration of risk forecasting, risk assessment and risk-based monitoring for the compliance profession. ...more

Compliance 2.0 and the Significance of HHS OIG’s 2017 Resource Guide: “Measuring Compliance Program Effectiveness”

by King & Spalding on

On March 27, 2017, in conjunction with the Health Care Compliance Association (“HCCA”) annual Compliance Institute (“CI”), the Department of Health and Human Services (“HHS”), Office of the Inspector General (“OIG”) released...more

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