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Day 24 of 31 Days to a More Effective Compliance Program-CCO Authority and Independence

by Thomas Fox on

The role of the Chief Compliance Officer (CCO) has steadily grown in stature and prestige over the years. In the 2012 FCPA Guidance, under Hallmark Three of the 10 Hallmarks of an Effective Compliance Program, the focus was...more

Bridging the Week - January 2018 #3

SEC Not Feeling Groovy About Cryptocurrencies – Tells Registered Investment Funds: Slow Down, You Move Too Fast: The Securities and Exchange Commission’s Division of Investment Management issued a letter to two industry...more

Day 23 of 31 Days to a More Effective Compliance Program-Updates and Feedback

by Thomas Fox on

One of the critical elements found in the Evaluation of Corporate Compliance Programs (Evaluation) is the need to use the information you obtain, whether through risk assessment, root cause analysis, investigation, hotline...more

SEC and CFTC Enforcement Directors Issue Joint Statement Regarding Virtual Currency Enforcement Actions

by Goodwin on

On January 19, 2018, SEC Co-Enforcement Directors Stephanie Avakian and Steven Peikin and CFTC Enforcement Director James McDonald issued the following joint statement regarding virtual currency enforcement actions...more

FCPA Compliance Report-Episode 367, Jim Shields on using comedy for compliance training

by Thomas Fox on

Today I visit with James Shields, the Creative Director for Twist and Shout Communications, a UK company which creates training video using comedy as the touchstone. You can check out a selection of the company’s offerings on...more

Day 22 of 31 Days to a More Effective Compliance Program- Assessing Compliance Internal Controls

by Thomas Fox on

In the Evaluation, Under Prong 9 Continuous Improvement, Periodic Testing and Review, it stated "Control Testing - Has the company reviewed and audited its compliance program in the area relating to the misconduct, including...more

Day 21 of 31 Days to a More Effective Compliance Program-Continuous Improvement in a Compliance Program

by Thomas Fox on

Under Hallmark Nine of Ten Hallmarks of an Effective Compliance Program as articulated in the 2012 FCPA Guidance, it stated, "Finally, a good compliance program should constantly evolve. A company's business changes over...more

Day 20 of 31 Days to a More Effective Compliance Program-Responding to Investigative Findings

by Thomas Fox on

There is nothing like an internal whistleblower report about a FCPA violation, the finding of such an issue or (even worse) a subpoena from the DOJ to trigger the Board of Directors and senior management attention to the...more

CFTC Proposes Interpretation of “Actual Delivery” for Virtual Currencies

by Latham & Watkins LLP on

The proposed interpretation would further clarify the CFTC’s jurisdiction over virtual currency platforms that facilitate retail commodity transactions. On December 15, 2017, the US Commodity Futures Trading Commission...more

AML extended to digital currencies - The 'Bitcoin amendments'

by Dentons on

Digital currency providers will soon be required to adhere to the AML/CTF standards required for remittance sector providers. Providers will be required to...more

Day 17 of 31 Days to a More Effective Compliance Program-Managing Your Third Parties

by Thomas Fox on

The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the lifecycle management of third parties, most compliance practitioners understand the need for a...more

Compliance Man Goes Global - Episode 8: Tough Questions

by Thomas Fox on

Welcome to Episode 8 of Compliance Man Goes Global podcast of FCPA Compliance Report International Edition. In this episode, we will focus on tough questions, which Compliance officers need to address. We will explore this...more

Day 16 of 31 Days to a More Effective Compliance Program-the Third-Party Risk Management Process

by Thomas Fox on

As every compliance practitioner is well aware, third parties still present the highest risk under the Foreign Corrupt Practices Act (FCPA). The Department of Justice Evaluation of Corporate Compliance Programs devotes an...more

Day 15 of 31 Days to a More Effective Compliance Program-How Do You Evaluate a Risk Assessment?

by Thomas Fox on

After you complete your risk assessment, you must then translate it into a risk profile, as Rick Messick has noted, to estimate where bribery is likely occur, so prevention efforts will be properly targeted. Ben Locwin...more

Day 14 of 31 Days to a More Effective Compliance Program- Risk Assessments

by Thomas Fox on

One cannot really say enough about risk assessments in the context of an anti-corruption program. Since at least 1999, in the Metcalf & Eddy enforcement action, the DOJ has said that a risk assessment, which measures the...more

Day 13 of 31 Days to a More Effective Compliance Program

by Thomas Fox on

In the Department of Justice’s Evaluation of Corporate Compliance Programs, Prong 8 Incentive and Disciplinary Measures it states: Incentive System – Consistent Application – Have the disciplinary actions and incentives been...more

Day 12 of 31 Days to a More Effective Compliance Program-Financial Incentives for Compliance

by Thomas Fox on

One of the areas that many companies have not paid as much attention to in their compliance programs is compensation. However, the DOJ and SEC have long made clear that they view monetary structure for compensation, rewarding...more

This Week in FCPA-Episode 84, the Playoffs are Here (for the Patriots) edition

by Thomas Fox on

In this episode, Jay Rosen and myself take a look at some of the top compliance stories over the past week. 1. Does Free Speech exist at the office? Can you tell your boss what you think of them? Ben DiPietro looks at a...more

Across the Board-Episode 12, Prudent Discharge of Board Compliance Obligations

by Thomas Fox on

In this episode I consider the obligations of a Board of Directors for a compliance program and how they may prudently discharge that obligation under Delaware case law, SEC regs, US Sentencing Guidelines and the Ten...more

Day 15 of 31 Days to a More Effective Compliance Program-How Do You Evaluate a Risk Assessment?

by Thomas Fox on

After you complete your risk assessment, you must then translate it into a risk profile, as Rick Messick has noted, to estimate where bribery is likely occur, so prevention efforts will be properly targeted. Ben Locwin...more

FINRA Targets ICOs and Digital Currencies in Annual Broker Exam Priorities Letter

by Goodwin on

On January 8, 2018, the Financial Industry Regulatory Authority (FINRA) released its 2018 Annual Regulatory and Examination Priorities Letter (Exam Priorities Letter) for its broker-dealer members. In the Exam Priorities...more

Compliance into the Weeds-Episode 65-The Trouble with Non-GAAP Metrics

by Thomas Fox on

In this episode Matt Kelly and I take deep dive into the issue of non-GAAP metrics and its implications. We were inspired an article in this quarter's MIT Sloan Management Review entitled, "The Pitfalls of Non-GAAP Metrics"...more

Day 10 of 31 Days to a More Effective Compliance Program-The Use of Social Media in Compliance

by Thomas Fox on

What is the message of compliance inside of a corporation and how it is distributed? In a compliance program, the largest portion of your consumers/customers are your employees. Social media presents some excellent mechanisms...more

Compliance Report-International Edition, RS Legal Strategies

by Thomas Fox on

Today, I visit with Mark Rainsford and Jason Sugarman, principals with RS Legal Strategies which is a pioneering Queen’s Counsel led business focusing on criminal investigations, fraud and legal strategy. ...more

Day 9 of 31 Days to a More Effective Compliance Program-360 Degrees of Compliance Communications

by Thomas Fox on

A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and visible to your employees at all times. It is about creating a distinctive...more

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