News & Analysis as of

Reading between the Headlines: A Lesson in Risk Mitigation from Edward Snowden

Whistleblowing has become a highly charged term, stirring up emotive rhetoric ranging from “ethical hero” to “treasonous traitor” with very little substantive evaluation of the real impact on the corporation and the broader...more

The European Commission Unveils its First EU Anti-Corruption Report, Highlighting the Continuing Risk of Corruption in EU Member...

On February 3, 2014, the European Commission published its first Anti-Corruption Report (the “Report”). The Report covers all types of corruption, including political corruption, bribery of public officials, and private or...more

For FCPA Compliance, Tone At The Top Key, Lack of Policies A Difficulty

The number of FCPA enforcement actions brought in recent years has declined. The SEC, for example, reports that in fiscal 2013 it brought 8 cases, compared to 10 in 2012 and 15 in 2011. Nevertheless, those who might be...more

Proprietary Trading Aspects of the Volcker Rule – Frequently Asked Questions

The Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission (the “SEC”) issued a final rule, and the Commodity Futures...more

The One New Year’s Resolution Your GRC Program Must Follow

It’s that season of the year, isn’t it? As we wrap up 2013 and make that final push for our sales goals and corporate objectives, we need to both look back at where we were and look ahead to what we want to do better....more

SEC Adopts Changes to Broker-Dealer Net Capital and Financial Responsibility Rules

The US Securities and Exchange Commission recently adopted important changes to the financial responsibility rules for securities broker-dealers, including changes to the regulatory capital and regulatory reporting rules. The...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

From The Compact Model To The Luxury Model – Managing Your Third Party Risk

I am currently attending the Hanson Wade Oil and Gas Supply Chain Compliance conference in Houston. The event is excellent and the presentations have been ‘spot on’ for the nuts and bolts of how to do compliance. As the...more

FINRA Issues 2013 Regulatory and Examination Priorities Letter

Overview: On January 11, 2013, the Financial Industry Regulated Authority (FINRA) issued its 2013 Annual Regulatory and Examination Priorities Letter (Priorities Letter). This letter is issued annually to highlight...more

FFIEC Issues Proposed Guidance on Social Media Risks and Compliance

The Federal Financial Institutions Examination Council (FFIEC) released a proposed guidance regarding the applicability of consumer protection, compliance and privacy laws to social media usage by banks, credit unions, and...more

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