News & Analysis as of

The Mitford Sisters and the Compliance Audit

Deborah Cavendish died last week. She was the last surviving member of an extraordinary group of women known as the ‘Mitford Sisters’. They were six daughters of David Freeman-Mitford, the 2nd Baron Redesdale and the former...more

How To Strengthen Your Ethics And Compliance Policy Management

People say that hindsight is 20/20. I’d say from my experiences its true. If only we could have 20/20 vision before an incident occurs, think of all the heartaches and headaches we could avoid. It would be especially helpful...more

12 Trends in Employment Discrimination Litigation: Proactive Employers See Fewer Claims

Fresh off a presentation on retaliation claims and defense at The American Conference Institute Employment Discrimination Litigation Conference in New York City, Dinsmore employment attorney Mike Hawkins shared 12 key trends...more

Risk Assessments-the Cornerstone of Your Compliance Program, Part II

One of the questions that I hear most often is how does one actually perform a risk assessment? Mike Volkov has suggested a couple of different approaches in his article “Practical Suggestions for Conducting Risk...more

Expanding Liability for Audit Committee Members

When one considers the corporate bureaucracy designed to ensure good corporate citizenship, the audit committee stands out. No committee of the board has the broad ranging purview of the audit committee, and those powers and...more

Corporate and Financial Weekly Digest - Volume IX, Issue 11

In this issue: - NASDAQ Launches Marketplace for Private Companies - SEC Proposes Rules to Enhance Oversight of Clearing Agencies - FINRA Proposes to Amend Rules 2210 and 2214 - CME Group Exchanges...more

The Federalist Papers And A Federated Approach To GRC

Today we celebrate one of America’s greatest political commentaries, The Federalist Papers. They were penned by James Madison, Alexander Hamilton and John Jay. They presented their three views on why the Federal Constitution...more

OCC Releases Guidelines on 'Heightened Expectations' for Large National Banks and Savings Associations

The Office of the Comptroller of the Currency (OCC) recently released proposed amendments to its Part 30 regulations, which reflect the agency's "heightened expectations" for large banks. That release, styled as an "Interim...more

OCC Releases Guidelines on ‘Heightened Expectations’ for Large National Banks and Savings Associations

The Office of the Comptroller of the Currency (OCC) last week released proposed amendments to its Part 30 regulations, which reflect the agency’s “heightened expectations” for large banks. That release, styled as an “Interim...more

Key Trends, Issues and Best Practices in Compliance 2013

NAVEX Global services the largest ethics and compliance community in the world. This survey is one example of our commitment to identify and communicate key trends and issues critical to business success. This independently...more

CFTC Approves Final Rules Enhancing Protections Afforded Customers and Customer Funds Held by Futures Commission Merchants

The CFTC approved final rules requiring enhanced protections afforded customers and customer funds held by futures commission merchants (“FCMs”). The rules require FCMs to adopt and enforce a risk management program,...more

Risk Sampling: The Key To A Successful Audit And Monitoring Program

Companies are always trying to do more with less. Senior executives will spend hours designing policies and programs to stretch dollars, resources and reduce costs. ...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

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 High-Risk Audits

The Justice Department and the SEC should be credited with promoting new compliance strategies and best practices. Whatever you may think about the DOJ/SEC FCPA enforcement program, they have pushed businesses to enhance...more

Third Party Risks And Internal Auditors

You remember the corny song – “People who need people are the luckiest people in the world.” For a Chief Compliance Officer that saying is particularly important when it comes to third party risks. CCOs need their...more

Inside Out: NASDAQ Proposes Rule To Require Internal Auditing

The NASDAQ Stock Market recently submitted a proposed rule change that would require all companies listed on the NASDAQ to maintain an internal audit function. The function would “provide management and the audit committee...more

Proposed Nasdaq Rule Would Require an Internal Audit Function at All Listed Companies

The NASDAQ Stock Market LLC (Nasdaq) recently filed with the Securities and Exchange Commission (SEC) a proposed rule requiring listed companies to establish and maintain an internal audit function. The SEC is soliciting...more

Nasdaq Proposes Listed Companies Have Internal Audit Function

The SEC has published for comment Nasdaq’s rule proposal that Nasdaq listed companies have an internal audit function. The rule proposal is as follows...more

A Roadmap for Audit Committees in Meeting the Challenges Posed by Enhanced Regulatory Scrutiny Under the Dodd-Frank Act

Audit committees must aid management in navigating an increasingly complex regulatory framework. Two recent developments arising from the passage and implementation of the Dodd-Frank Act have led to further challenges for...more

FFIEC Proposed Guidance on Social Media Risk Management: Practice Points for All Organizations Using Social Media

Organizations using social media are confronted with an ever increasing challenge of social media risk management. To help financial institutions identify, measure, monitor, and control such risks, the Federal Financial...more

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