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CCO

NAVEX

From Healthcare Sector, a Big Push for CCO Autonomy

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For the better part of a decade, the U.S. Justice Department has led the way on calls for a strong, independent corporate compliance function – until recently, that is. Then the Department of Health and Human Services leaped...more

Society of Corporate Compliance and Ethics...

Navigating CCO liability risks: Tips for staying out of the SEC's crosshairs

The issue of chief compliance officer (CCO) liability has long been debated; it has become a grave concern for CCOs, CEOs, and other C-suite executives who put on “too many hats” within an organization and take on the firm’s...more

Buckingham, Doolittle & Burroughs, LLC

Dear YouDig? How to Avoid Close Out Chaos

Dear YouDig?, It has been a struggle lately. We don’t have trouble getting work. In fact we are booming. The problem: We can’t seem to close out a project without email accusations, letter campaigns, lawyers and a whole...more

Harris Beach PLLC

Two Executives and Distributor Charged for Unlawfully Distributing Controlled Substances

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Rochester Drug Co-Operative, Inc. (“RDC”), one of the 10 largest pharmaceutical distributors in the United States, was recently charged along with its former Chief Executive Officer and former Chief Compliance Officer, for...more

Thomas Fox - Compliance Evangelist

The Updated Evaluation Of Corporate Compliance Programs – Guidance Document: Part I – Introduction

As I noted in yesterday’s blog post, at the Ethics and Compliance Initiative (ECI) Impact 2019 Conference, Assistant Attorney General Brian Benczkowski announced (ECI speech) an update to the 2017 Evaluation of Corporate...more

Blank Rome LLP

Regulatory Update and Recent SEC Actions - January 2019

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Fund and Investment Management January 2019 (No. 1) REGULATORY UPDATES Policy Initiatives Set Forth by the U.S. Securities and Exchange Commission’s (“SEC”) Investment Management Division On September 28, 2018, Division of...more

Vedder Price

Investment Services Regulatory Update - October 2018

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New Rules, Proposed Rules, Guidance and Alerts - SEC STAFF GUIDANCE AND ALERTS – SEC Staff No-Action Letter Allows Fund Boards to Rely on CCO Representations for Affiliated Transactions – In a no-action letter to the...more

Dechert LLP

Fund Boards May Rely on CCO Representations in Lieu of Quarterly Board Determinations Under Rules 10f-3, 17a-7 and 17e-1

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The Staff of the SEC’s Division of Investment Management has issued a no-action letter permitting a fund’s board to rely on written representations from the fund’s CCO in lieu of quarterly determinations that the fund’s...more

Thomas Fox - Compliance Evangelist

Lincoln and Transformative Leadership – Part II

When faced with a compliance issue or an obstacle you should endeavor to keep everything on an even keel and never let them see you sweat. ...more

Proskauer - The Capital Commitment

Five Things to Think About Before a Surprise SEC Exam

If a team from the SEC arrives at your office and says, “We are conducting an on-site examination and would like to talk to the CCO right now,” are you prepared? A handful of registered investment advisers have faced surprise...more

The Volkov Law Group

No More Excuses: CCOs Have to Embrace Technology

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It is time for an honesty check – many CCOs do not like change. CCOs, however, need to embrace change as a powerful force. Compliance is an evolutionary process – it is constantly changing. A compliance program has to move...more

Baker Donelson

Protecting Privilege of the Corporate Compliance Officer

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The Corporate Compliance Officer (CCO) acts as the organizational conscience overseeing the compliance program. Corporate integrity promotes a strong brand reputation, avoids high-profile failures and contributes to a strong...more

The Volkov Law Group

The Power of Honesty – A Candid Assessment of Your Compliance Program

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The secret of life is honesty and fair dealing. If you can fake that, you’ve got it made.  Groucho Marx - We are all taught the importance of honesty. But there are very different aspects to this otherwise simple...more

Thomas Fox - Compliance Evangelist

Compliance Expertise Needed on the Board

This week I have been exploring the different types compliance committee’s which an organization can utilize to help effect a best practices compliance program. I have written about compliance committee’s at the Board of...more

The Volkov Law Group

Hiding Behind the Privilege – A Cloak or a Dagger?

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CCOs face many challenges in their jobs. One area that is difficult but usually can be solved with common sense is where to draw the line on attorney-client privilege issues. As a practicing attorney, I can attest to the...more

NAVEX

Top 10 Ethics & Compliance Predictions and Recommendations for 2017

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Once again it’s time for our annual review of trends and events that will impact your Ethics and Compliance (E&C) program in the year ahead. This year presents a unique challenge. We are preparing our predictions...more

Manatt, Phelps & Phillips, LLP

BSA/AML Violations Trigger $215M Consent Order With New York's DFS

Violations of state anti-money laundering laws tripped up the Agricultural Bank of China, which recently entered into a consent order with New York's Department of Financial Services for $215 million....more

Manatt, Phelps & Phillips, LLP

Manatt on Health Reform: Weekly Highlights - November 2016 #2

CMS authorizes Massachusetts waiver supporting transition to a Medicaid ACO model; Oregon CCOs use “flexible service” funds to invest in housing-related services; and enrollment for 2017 Marketplace coverage begins....more

NAVEX

[Webinar] 2016 Ethics & Compliance Virtual Conference - Harnessing the Business Value of an Ethical Culture - November 15th,...

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Join professionals in ethics and compliance, human resources, legal, audit and training for the annual 2016 Ethics & Compliance Virtual Conference! Learn strategies to help you build a better governed, more risk-aware, and...more

King & Spalding

Oregon Requests $1.25 Billion from CMS to Expand Medicaid Coordinated Care Model Demonstration Waiver

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Oregon has requested $1.25 billion in federal funding to expand the Oregon Health Plan (OHP), a coordinated care model implemented under Section 1115(a) of the Social Security Act. The current OHP Section 1115 demonstration...more

McGuireWoods LLP

SEC Enforcement Chief Andrew Ceresney Discusses CCO Liability

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On November 4, 2015, Andrew Ceresney, director of the Securities and Exchange Commission’s (SEC’s) Division of Enforcement (Enforcement Division), delivered the keynote address at the 2015 National Conference of the National...more

NAVEX

Top Ten Resources for Engaging Your Board in Your Ethics & Compliance Program

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Resources to help you engage your board of directors in the success of your ethics and compliance program. A successful board engagement strategy can help ethics and compliance professionals gain significant program...more

Dechert LLP

SEC Issues Settled Enforcement Action Against Investment Adviser, its President and Senior Officers for Compliance Program...

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The U.S. Securities and Exchange Commission (SEC or Commission) issued a cease and desist order (Order) on June 23, 2015, against Pekin Singer Strauss Asset Management Inc. (Adviser), an investment adviser registered under...more

Dechert LLP

SEC Proposes to Amend Form ADV and Investment Adviser Recordkeeping Rules

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The U.S. Securities and Exchange Commission (SEC or Commission) recently proposed amendments to Form ADV and to Rule 204-2 (Recordkeeping Rule) and other rules under the Investment Advisers Act of 1940, as amended (Advisers...more

Thomas Fox - Compliance Evangelist

Senn Interview, Part I – Investigations Under the FCPA

One of the things that I am questioned on is when to bring in outside counsel for a Foreign Corrupt Practices Act (FCPA) investigation or simply to take a look at an issue that may have raised a Red Flag but is not yet a FCPA...more

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