How can business owners manage legal risks?
Compliance Advice on SEC’s Market Access Rule from Julie Dixon of Titan Regulation
Higher Education Oversight and Governance: Role of a College Board of Trustees
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
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
For years organizations have used training to successfully build legal defenses and better position their organizations against litigation and enforcement actions. Increasingly though, training is intended to serve a dual...more
The Office of the Comptroller of the Currency (OCC) recently issued a new Bulletin 2013-29 containing substantially more onerous risk management guidance for third-party business relationships (3PRs) of national banks and...more
Compliance, like many other aspects of the business world, is a balance of risks. Unfortunately, it often takes an organization being rebuked in some fashion before it realizes the importance of failure to be in compliance. ...more
Designed right, an ethics and compliance program is not just about limiting risk. You’re setting your sights too low. In fact with that narrow mindset, you’re likely setting your organization up for failure, or at least...more
What's the one thing missing from most corporate compliance programs?
For a legal perspective, that's the question we put to corporate attorneys writing on JD Supra, asking each to commit to just one essential element...more
On October 30, the Office of the Comptroller of the Currency (OCC) issued guidance (Bulletin 2013-29) to national banks and federal savings associations (collectively, banks) for assessing and managing risks associated with...more
On October 31, the Federal Reserve Board released a BSA/AML enforcement action against a Pakistani bank and its New York branch. The Written Agreement addresses examiners’ findings of alleged compliance and risk management...more
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
Companies are paying more attention to strategic risk management. The reasons for this are not just the aggressive enforcement environment but the technological age in which we live....more
Most organizations engage with hundreds, if not often thousands, of third party vendors, suppliers, agents and business partners, creating a daunting and ever-expanding scope of risk.
This risk arises from:
The privilege to serve on a corporate board is no longer the cushy experience of our forefathers. The increase in enforcement actions has led to a dramatic change in the role – and the risks – facing corporate boards....more
With certain EMIR provisions set to go live in September, both EU counterparties and many non-EU counterparties must take action to comply with risk management requirements, which involve some overlap with Dodd-Frank....more
On 4 September 2013, the European Commission published a long-anticipated communication that detailed far-reaching plans to reform the shadow banking industry. The envisaged reform project anticipates a five point approach,...more
The Chinese Government’s wide-ranging bribery and corruption investigation into the pharmaceutical industry takes a new turn every week. Media reports contain numerous incidents of purported whistleblowers making allegations...more
NAVEX Global and PwC recently sponsored a groundbreaking study from the Ethics Resource Center around Social Networking in the workplace. There was a lot covered in the study, so we’ve put the results in context for ethics...more
Please see full Infographic below for more information....more
Multinational companies operating in the country should adapt their compliance programs in light of the risk of civil and criminal penalties.
Fraudulent official receipts — or "fapiao"(the Chinese word for an official...more
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
This column may be another example of what I call — “ A profound grasp of the obvious.” ...more
Large companies have the resources and the incentive to implement risk management systems. ...more
As technology continues to increase the efficiency of most operational tasks, it should come as little surprise that technology can now improve the labor-intensive process of managing third party risk. The days of manual...more
We have all watched the familiar scene on Capitol Hill – the latest public scandal like officials from the Internal Revenue Service are dragged up to Capitol Hill to appear before a Committee, raise their right hands, take...more
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