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Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -

Farewell to Sammartino: The Continued Unraveling of PDVSA Corruption

by Thomas Fox on

Yesterday Cesar David Rincon Godoy (Rincon) pled guilty to a massive money laundering scheme which took the proceeds of his corruption while he was employed at PDVSA. According to the DOJ Press Release, Rincon, a citizen of...more

Risk technology: What’s driving new GRC investment?

As enterprise risk technology evolves to meet a more diverse and exacting range of demands, what are the key drivers prompting banks and financial institutions to consider fresh governance, risk and compliance (GRC)...more

Farewell to Barbara Bush: The Role of a Compliance Committee Chair – Part II

by Thomas Fox on

The role of a Chief Compliance Officer (CCO) is that of a doer. However, if you move up to the Board of Directors and become the Compliance Committee Chair, your role changes. ...more

AML Compliance Lessons Learned from US Bancorp and Rabobank Enforcement Actions

by Michael Volkov on

Global banks have been the focus of enforcement actions, focusing on AML and sanctions violations.  With the new beneficial ownership regulations effective May 11, 2018, we are about to see a significant transformation in AML...more

Farewell to Hall Greer: The Role of a Compliance Committee Chair – Part I

by Thomas Fox on

I continually advocate that a Boards of Directors should include a compliance professional and that there should be a Compliance Committee Chair on the Board, handling ethics, compliance, #MeToo and other reputational issues,...more

Tackling data overload with intelligent tagging

Today’s data-rich environment is a double-edged sword for compliance professionals, with regulatory change or KYC adding to the risk of information overload. How can machine learning and intelligent tagging help?...more

Compliance with Contractual Provisions to Procure Insurance: The Illusion of Coverage Provided by Certificates of Insurance

by Jaburg Wilk on

Commercial contracts often require the party with less bargaining power to procure insurance for the party with more bargaining power as a way to shift risk and potential liability. General Contractors often require a...more

CCOs and Compromising Positions

by Michael Volkov on

The chief compliances officer is the guardian of a company’s most important intangible asset – its culture. Everyone at a company is responsible for a company’s culture; the board of directors, CEO, senior executives play an...more

Learning the Basics on GDPR’s Right to Be Forgotten

by NAVEX Global on

Now that the European Union’s General Data Protection Regulation is nearly here, it’s time for ethics and compliance officers to panic more efficiently about all the challenges that lie ahead....more

How sanctions-proof is your Source of Wealth due diligence?

U.S. sanctions against Russian oligarchs and their associated companies demonstrate the value of Source of Wealth due diligence assessments that go beyond simply identifying the assets owned....more

Leadership Lessons from James Polk – Mind the Details but Don’t Take Your Eyes off the Goal

by Thomas Fox on

There were two economic issues that Polk accomplished which greatly furthered US economic interests. The first was the reduction of the Tariff of 1842. Polk directed Secretary of the Treasury Robert Walker to draft a lower...more

[Webinar] Preparing for New York State and New York City’s New Sexual Harassment Prevention Mandates: What Employers Should...

by Jackson Lewis P.C. on

New York State and New York City each have passed sweeping measures intended to combat harassment in the workplace. Mayor Bill de Blasio is expected to sign the New York City Council’s legislation into law soon. Similarly,...more

FinCEN Issues Guidance for Beneficial Ownership Regulations

by Michael Volkov on

Financial institutions face an important deadline – May 11, 2018 is the effective date for the new customer due diligence regulations governing beneficial ownership requirements. FinCEN provided financial institutions nearly...more

[Webinar] Master Class: Conducting & Closing Effective Workplace Investigations - May 10th, 8:30am PT

by NAVEX Global on

Join this free educational event—brought to you by the NAVEX Global Ethics & Compliance Virtual Conference—for 2.5 hours of quality learning. Become an expert investigator in 1 day! In this Master Class, you will learn...more

Innovation in Compliance Episode 5: The Future of Disrupting Risk with Dan Torpey

by Thomas Fox on

Dan Torpey is a forensic accountant CPA and former auditor with over 30 years of public accounting experience. He’s a partner at Ernst & Young and the US leader of EY’s Investigation and Compliance services. With all those...more

Does your compliance training solve a real problem? 

by Broadcat on

If you stopped doing compliance training tomorrow, would anything change at your company? That question determines whether your training solves a real problem—or if you're just doing it for the sake of doing it. That...more

Corp Fin Posts Two New CDIs Regarding Non-GAAP Financial Measures in the M&A Context

by White & Case LLP on

On April 4, 2018, the Securities and Exchange Commission’s ("SEC") Division of Corporation Finance ("Corp Fin") posted two new compliance and disclosure interpretations ("CDIs") regarding the use of non-GAAP financial...more

Nights in White Satin – The Continued Pain at Wells Fargo

by Thomas Fox on

The Wells Fargo scandals continue to be one of the starkest lessons about the cost of a corrupt culture and the catastrophic effect it can have on an organization. The former Chief Executive Officer (CEO) and head of the...more

Episode 34 -- The Cohen Criminal Investigation and the Search Warrants

by Michael Volkov on

On April 9, 2018, FBI agents executed search warrants at Michael Cohen's office, hotel, residence, safety deposit box and electronic devices. Since then, we learned that the US Attorney's Office in New York City have an...more

Corporate Criminal Liability – Perspectives from the US, UK and France

by Bryan Cave on

Shakespeare’s observation that the “past is prologue” certainly applies to corporate criminal liability in the UK and France, as these jurisdictions embrace with gusto corporate prosecutions akin to those pursued in the US...more

FinCEN Issues FAQs for Customer Due Diligence Rule; Compliance Required in May

by Dechert LLP on

The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) on April 3, 2018 issued Frequently Asked Questions Regarding Customer Due Diligence Requirements for Financial Institutions (FAQs). The FAQs address various...more

Operationalizing compliance through tailored compliance training

by Thomas Fox on

I have considered this in the context of third-parties, forecasting and the risk management process and through the use of a root cause analysis. Today, I want to conclude this week’s blog posts with a post on...more

What enforcement tools are in the armoury of prosecutors in the US, UK and France?

by Bryan Cave on

Summary: Deferred prosecution agreements have been widely used by US prosecutors since the early 2000s. Prosecutors in the UK and France only obtained this power in 2014 and 2016 respectively – but they are making up for...more

Customer Due Diligence Deadline Nears

by Harris Beach PLLC on

Financial institutions face a pending deadline to meet new customer due diligence requirements. FinCEN has issued updated Frequently Asked Questions to assist financial institutions in understanding the scope of the...more

Operationalizing Compliance Through a Root Cause Analysis

by Thomas Fox on

This week I have been exploring how you can work to operationalize your compliance programs in ways you perhaps had not considered previously. Today I want you to consider Prong 1 of the Evaluation of Corporate Compliance...more

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