Risk Management

News & Analysis as of

Banking Regulators Release Advanced Notice of Proposed Rulemaking on Enhanced Cyber Risk Management Standards

Yesterday, the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (Fed), and the Federal Deposit Insurance Corporation (FDIC) issued a joint advanced notice of proposed rulemaking (ANPRM) seeking...more

Federal Banking Agencies Propose New Requirements for Managing Cyber Risk

Three federal banking agencies have announced plans to develop new rules that would establish cyber risk management and resiliency standards for large interconnected entities under the agencies' supervision, as well as those...more

Bank Regulators Issue Notice of Proposed Rulemaking on Enhanced Cyber Risk Management Standards

Three federal banking regulatory agencies have approved an advance notice of proposed rulemaking (ANPR) inviting comment on a set of potential enhanced cybersecurity risk-management and resilience standards that would apply...more

European Health Care Compliance Challenges (And Solutions)

Life sciences and health care companies (“health care companies”) rightly invest a significant amount of time and money into ensuring compliance with health care regulations in the countries in which they are based, but...more

Like a Rolling Stone and the Failures of Internal Controls

I continue my celebration of Bob Dylan, Nobel Laureate, by reflecting on what many consider to be his greatest recording, Like a Rolling Stone. In 2004, Rolling Stone magazine named it as the greatest song of all time....more

Don't Post That! Protecting Patient Privacy in the Age of Social Media

Social media has great utility for urgent care centers, providing invaluable opportunities to connect with the local community, and offering a host of educational tools for providers and patients. The explosion of myriad...more

5 Challenges in International Fraud Investigations. Alexis Bell, Fraud Doctor, Explains

Alexis Bell, CEO of Fraud Doctor LLC, discusses challenges in fraud investigation overseas. At least 5 different ways your fraud investigation can be impacted when it is conducted internationally...more

DOJ and SEC Raising the Stakes on Third Party Risk Management

If you review the last ten years of FCPA enforcement, the unmistakable pattern is rising expectations with regard to corporate compliance programs, particularly with regard to third party due diligence and risk management....more

FCPA Compliance Report-Episode 286-Use of Technology in Supply Chain Risk Management [Video]

Software platforms can provide a lot of efficiencies such as a reduction of time, resources and a more manageable audit trail. Still, software cannot do everything. Subject matter expertise is still essential to building a...more

Stinson Leonard Street's Emerging Trends Newsletter - Q3

We are thrilled to bring you the third installment of Stinson Leonard Street's Emerging Trends newsletter. We are proud of the depth and breadth of experience and knowledge across our firm's 13 offices nationwide and are...more

The New York State Department of Financial Services Proposes Robust Cybersecurity Rules

On September 13, 2016, the New York State Department of Financial Services (DFS) proposed new rules that would require certain “Covered Entities” to establish and implement cybersecurity programs designed to protect nonpublic...more

How Much Do You Spend on Cybersecurity…and on What?

Fortune.com reported that according to an International Data Corporation (IDC) forecast, by 2020, spending on security-related hardware, software, and services will eclipse $100 billion. However, consulting company NTT Com...more

Regulatory Update: SEC Adopts New Requirements for Fund Liquidity Risk Management and Amendments to Permit the Use of “Swing...

On October 13, 2016, the U.S. Securities and Exchange Commission (SEC) unanimously adopted regulatory changes that require open-end funds, including mutual funds and exchange-traded funds (ETFs), to establish liquidity risk...more

SEC Approves Liquidity Risk Management Rules for Mutual Funds and ETFs

On October 13, 2016, at an open meeting, the U.S. Securities and Exchange Commission (SEC) voted to approve three rules designed to enhance effective liquidity risk management by open-end funds, including mutual funds and...more

OCR Issues Guidance on HIPAA and Cloud Computing

On October 7, 2016, the U.S. Department of Health and Human Services (“HHS”), Office for Civil Rights (“OCR”), released a guidance document (the “Guidance”) on the HIPAA-compliant use of cloud computing technologies. The...more

Monster Movie Month: Episode 2 – The Bride of Frankenstein and Upcoming Events

Welcome to my second installment in this month’s classic monster movie festival. This year I am revisiting the Frankenstein series and today I want to explore and, indeed, honor the second in the series but what many viewers...more

Orrick's Financial Industry Week In Review

Financial Industry Developments - The CFPB Publishes Final Rule for Prepaid Accounts - On October 5, 2016, the Consumer Financial Protection Bureau (the "CFPB") finalized comprehensive consumer protections for...more

SEC Approves New Liquidity Risk Management Rules; Swing Pricing Rules

The SEC today unanimously approved “transformational” new rules requiring liquidity risk management programs. The SEC also approved a swing pricing rule by a vote of 2-1, with Commissioner Piwowar voting against...more

De-Risking 101

Bank Secrecy Act of 1970 - Requires U.S. financial institutions to assist U.S. government agencies to detect and prevent money laundering by keeping records of cash purchases of negotiable instruments, and file reports...more

Draft Cybersecurity Self-Assessment Tool Published

The National Institute of Standards and Technology (NIST) recently published a draft cybersecurity self-assessment tool entitled “The Baldrige Cybersecurity Excellence Builder,” which provides organizations with a tool to...more

The OCC Publishes Guidance Concerning Foreign Correspondent Banking Accounts

On October 5, 2016, the Office of the Comptroller of the Currency (the “OCC”) issued risk management guidance that addresses periodic reevaluations of risks associated with foreign correspondent banking accounts. The guidance...more

When just saying “no” is a good thing

In the hectic world of financial services, registered representatives and investment adviser representatives are always looking to increase their assets under management. At what cost? Are there situations where you would be...more

John Fogarty Rocks-Nu Skin Informs Oversight

I recently saw John Fogerty in concert. For those you are not aware, he was a founding member and the driving force behind Creedence Clearwater Revival (CCR), one of the very top American groups from the 1960s and early...more

Five Ways to Prepare for Business Interruption Insurance Claims in a Natural Disaster

The extraordinary images and reports of the devastation from Hurricane Matthew have filled the news outlets. While the focus remains on the human toll and concern for the well-being of friends, colleagues and business...more

What You Must Know about New York’s Proposed Cybersecurity Regulation for the Banking, Insurance, and Financial Services Sectors

Last week, New York’s Department of Financial Services released its long-awaited proposed cybersecurity regulation, which promises to deliver sweeping protections to consumers and financial institutions alike. The proposed...more

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