News & Analysis as of

Third-Party Compliance

Investment Services Regulatory Update - August 2017

by Vedder Price on

On August 7, 2017, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert providing a summary of the staff’s observations from sweep exams of broker-dealers, investment advisers and funds...more

Day 17 of One Month to More Effective Continuous Improvement-Financial Health Monitoring

by Thomas Fox on

Continuous improvement can take many ways, shapes and forms. Typically, when it comes to third-party risks, a Chief Compliance Officer (CCO) or compliance professional will consider the ownership structure to see if there is...more

Tokyo Dispute Resolution & Crisis Management Newsletter – March 2017

by King & Spalding on

US Department of Justice Issues New Corporate Compliance Guidelines - Criteria for the Criminal Division’s Evaluation of Corporate Compliance Programs - Introduction - Recently, and without the fanfare that often...more

DOJ Issues New Corporate Compliance Guidelines; Document Outlines Criteria for the Criminal Division’s Evaluation of Corporate...

by King & Spalding on

Recently, and without the fanfare that often accompanies new policy guidance regarding corporate fraud, the Fraud Section of the Department of Justice posted a document on its website entitled “Evaluation of Corporate...more

Insight from the DOJ Fraud Section

by Robins Kaplan LLP on

Without fanfare, on February 8 the Fraud Section of the Department of Justice (DOJ) published new corporate compliance guidance on its public website. The guidance is presented as a set of topics and questions, entitled...more

Four Things Compliance Practitioner Should Know About the Eurasian Economic Union

by Thomas Fox on

Four Things Compliance Practitioner Should Know About the Eurasian Economic Union - An effective Compliance risk management at emerging markets for any business significantly depends on timeous observation of changes in...more

The Compliance Oversight Review Committee

by Thomas Fox on

This week has evolved into an exploration of different types of compliance committees a company might employ to make their compliance function more effective. On Monday, together with Baker Hughes Incorporated (BHI) Chief...more

Due Diligence Basics – Beneficial Ownership

by Michael Volkov on

I hate to be the harbinger of bad news; that is against my nature; I am naturally an optimistic person. As I always say, there are solutions to every problem....more

Sampling as a Compliance Strategy

by Michael Volkov on

In the technology age in which we live, CCOs often come face to face with a new phenomenon – too much information or data. TMI is not something to laugh at nor ignore. CCOs often face situations where they need to understand...more

When Diligence is Not Given its “Due”

by Michael Volkov on

I find myself quibbling with compliance terms – hyper focus on small issues is not a positive trait. I often urge clients and colleagues to focus on issue of more significance and leave the smaller ones for another day....more

[Webinar] How do I Demonstrate the Advantages of an Automated Third Party Due Diligence System to Senior Leadership? - July 8th,...

by NAVEX Global on

Join NAVEX Global and a group of your peers for a short session where we’ll answer your questions and share solutions about third party due diligence and risk management software....more

The SEC, CCOs and Compliance Programs

by Dorsey & Whitney LLP on

Compliance programs, Chief Compliance Officers and liability have been the subject of a great deal of debate in recent months. Members of the Commission, for example, debated charging decisions regarding CCOs last year in...more

2015 Ethics & Compliance Third Party Risk Management Benchmark Report

by NAVEX Global on

Organizations are still coming to terms with the breadth and depth of their third party risk. An effective third party risk management program is in the interest of all organization —regardless of their size, industry, and...more

Weak Compliance Programs Won’t Protect You from Criminal Misconduct

by Baker Donelson on

The Department of Justice’s (DOJ’s) Criminal Division has now hired “Compliance Counsel” but the Department has no plans to move towards making a formal compliance defense available to those charged with regulatory...more

SEC to Recommend Additional Compliance Rules for Investment Advisers

by Foley Hoag LLP on

David W. Grim, Director of the SEC’s Division of Investment Management (the “Division”), recently noted in testimony before a U.S. House of Representatives subcommittee that the Division is developing new rule recommendations...more

Common FCPA Issues

by Foley & Lardner LLP on

As our previous posts illustrate, violations of the Foreign Corrupt Practices Act (“FCPA”) can carry a hefty cost. Two issues are commonly the impetus for FCPA violations and, practically speaking, pose significant FCPA...more

Focus on China - October 2015

by McDermott Will & Emery on

Welcome to the third issue of Focus on China Compliance for 2015. According to the FCPA Blog’s October 2015 Corporate Investigations List, China leads the countries reported to be involved in FCPA investigations with 29...more

OIG Reports Insufficient Oversight Of HIPAA Compliance

by King & Spalding on

The HHS Office for Civil Rights (OCR) must improve its oversight and enforcement of patient information privacy and security rules by “covered entities” and their business associates under the Health Information Portability...more

Is Your HIPAA Compliance Program Ready for the FTC?

Everyone in healthcare knows that the next round of HIPAA audits is coming. Covered entities and business associates have long been advised to review and update their HIPAA security risk analyses, have business associate...more

SEC Sets Compliance Date for Pay-to-Play Rule's Ban on Third-Party Solicitation of Government Entities

by Proskauer Rose LLP on

On June 25, 2015, the Securities and Exchange Commission (SEC) set a compliance date of July 31, 2015 for the ban on payments to third parties for the solicitation of advisory business from any government entity under Rule...more

Great Structures Week V – The Tacoma Narrow Bridge Failure and Preventing Failure in Your Compliance Program

by Thomas Fox on

I conclude my Great Structures Week with a focus on structural engineering failures: suspension bridges and the challenges of wind in their construction and maintenance. I am drawing these posts from The Great Courses...more

Agencies Issue Final Regulations on the Summary of Benefits and Coverage (SBC) Requirements

As promised in the FAQ issued on March 30, 2015, the U.S. Departments of the Treasury, Labor and Health and Human Services (the Departments) have issued final regulations regarding the summary of benefits and coverage (SBC)...more

The State of Anti-Bribery & Corruption Programs: Key Trends and Takeaways from Recent Research Report

by NAVEX Global on

Kroll and Compliance Week’s 2015 Anti-Bribery and Corruption Benchmarking Report, surveyed global compliance executives and revealed that, while compliance officers are aware of the risks of anti-bribery and corruption (ABC),...more

FCPA Compliance and Ethics Report-Episode 169-the First Mailbag Issue

by Thomas Fox on

In this inaugural Mailbag Episode, I field questions from an earlier podcast on the training of third parties under the FCPA. ...more

Are You a Government Subcontractor?

by Foley & Lardner LLP on

Just because your company does not contract directly with the government does not necessarily mean you are not subject to the many requirements associated with government contractors. Those who provide goods and services to...more

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