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Compliance Cyber Crimes

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. ... 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 -
Holland & Knight LLP

DOJ Brings Suit Against University Under Its Civil Cyber-Fraud Initiative

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Late last week, the U.S. Department of Justice (DOJ) filed its complaint-in-intervention in a qui tam lawsuit against the Georgia Institute of Technology (Georgia Tech), alleging that the university failed to meet certain...more

Katten Muchin Rosenman LLP

New Rules for Investment Advisers and Brokers Relating to Cybersecurity Breaches

On May 16, the Securities and Exchange Commission (SEC) unanimously approved amendments to Regulation S-P, which imposes new rules relating to cybersecurity breaches involving investment advisers and brokers. Larger entities...more

Guidepost Solutions LLC

Money Laundering, Terrorist Financing, and Investment Advisors – Yes, Financial Crime is Borderless and Legal Entity-Agnostic

There is a growing acknowledgement that money laundering and terrorist financing is borderless and legal entity-agnostic, just as it is already known that cybercriminals and the means to commit cybercrimes continuously attack...more

Guidepost Solutions LLC

Investment Advisers and Generative AI

Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

Foley & Lardner LLP

Health-Care Fraud Scrutiny Heats Up For Companies, Providers

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This year will see a continued proliferation of enforcement against health-care fraud, with old and new theories. Some hot spots for enforcement will involve cases about new technologies; data outliers; entities perceived as...more

Health Care Compliance Association (HCCA)

Privacy Briefs: October 2023

Report on Patient Privacy 23, no. 10 (October, 2023) Kaiser Foundation Health Plan Inc. and Kaiser Foundation Hospitals will pay California $49 million to resolve allegations that they unlawfully disposed of hazardous waste,...more

Epiq

Move it or Lose it – With Cyber Breach Response, Time is of the Essence

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There are so many factors that go into breach response. Determining the size of the breach, time limitations, legal requirements, notification needs, urgency for containment, and interrupted business operations are just a...more

K2 Integrity

SEC Division of Examination Risk Alert Highlights Deficiencies in Broker-Dealers’ AML Compliance Programs

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The U.S. Securities and Exchange Commission (SEC) is responsible for protecting investors and ensuring the integrity of the securities markets. As part of this mission, the SEC requires broker-dealers to comply with...more

The Volkov Law Group

Episode 282 -- CISO and CCOs -- The Evolving Partnership

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If you ask corporate board members and senior executives to list their number one risk (other than financial operations), the answer in today’s risk environment is clear – cybersecurity and data privacy. The rapid elevation...more

Proskauer - The Capital Commitment

The Trend Continues: Increased Regulatory Focus on Privacy & Cybersecurity for Private Funds

Recent enforcement actions highlight the increased regulatory scrutiny that private funds may face with respect to internal cybersecurity protocols and responses to cyber-crimes and cyber incidents under new and updated...more

Guidepost Solutions LLC

Focus on Foreign Banks’ Sanctions Compliance Programs in the U.S. and Globally - Upgrading and Empowering Compliance to Help...

As the Russia – Ukraine war rages on, one outcome so far is clear: the Western nations remain aligned and united to confront Russian aggression. The West’s synchronized, roll-out of economic and trade sanctions against...more

BakerHostetler

Former Uber Chief Security Officer Convicted of Federal Obstruction and Concealment Crimes in Connection with Extortionate Data...

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On October 5, 2022, a federal jury found Joseph Sullivan, Uber’s former chief security officer, guilty of obstruction of justice and misprision of a felony in connection with his role in responding to a 2016 data breach...more

WilmerHale

Aerojet Rocketdyne Agrees to Pay $9 Million to Resolve False Claims Act Allegations of Cybersecurity Violations in Federal...

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On July 8, 2022, the Department of Justice (“DOJ”) announced in a press release that Aerojet Rocketdyne Inc, a provider of advanced propulsion and energetics systems for multiple government agencies, reached a settlement...more

Mitratech Holdings, Inc

Where the Traditional HR Suite is Falling Short: Ensuring Compliance Across Borders

How to complete forms properly, save time on the review process, and ensure compliance during the hiring process! HR teams worldwide are reaping the benefits of the shift to a remote and hybrid work model; hiring from a...more

American Conference Institute (ACI)

Compliance measures to address sanctions enforcement: ‘the new FCPA’

In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more

Baker Donelson

Cybersecurity: A Whistleblower's Paradise

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Cyber whistleblowing is the newest and hottest area of exposure for organizations. All government contractors and grant recipients must develop an understanding of the use of the False Claims Act (FCA) to address...more

BakerHostetler

$3.6 Billion Reasons to Up Cryptocurrency Compliance: FBI Cracking Down on Crypto Criminals

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Key Takeaways - ..Banks and cryptocurrency exchanges need to update their BSA programs to account for the unique aspects of cryptocurrencies, detect and report related suspicious activity, and minimize the risk of...more

Alston & Bird

Incomplete Cybersecurity Compliance Disclosures May Support Fraud Claim Under the False Claims Act, Federal Court Holds

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At the heels of a recent Civil Cyber-Fraud Initiative related to cybersecurity practices and the False Claims Act (FCA), a cybersecurity-related FCA case has survived a motion for summary judgment, teeing up a trial to...more

BakerHostetler

DOJ Criminal Division Head Kenneth Polite Cautions Compliance Crackdown

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Key Takeaways - Corporate enforcement and individual accountability are high priorities for new DOJ Criminal Division head Kenneth Polite. Companies should be proactive in implementing, monitoring, and improving their...more

Steptoe & Johnson PLLC

Department of Justice Wants Corporate Compliance Plans on the "Front Burner"

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New Department of Justice (“DOJ”) Criminal Chief Kenneth Polite was recently interviewed about his efforts to reinvigorate federal white-collar crime prosecutions. DOJ’s new priorities will include investigations of corporate...more

Woods Rogers

Department of Justice Announces New Civil Cyber-Fraud Initiative – What This Means for Federal Contractors

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Recently, Deputy Attorney General Lisa O. Monaco announced the Department of Justice’s new Civil Cyber-Fraud Initiative, aimed at combatting “new and emerging cyber threats to the security of sensitive information and...more

Sheppard Mullin Richter & Hampton LLP

OFAC Enforcement Impacts NFTs: As Crypto Enforcement Ramps Up to Combat Ransomware, Robust Compliance is Key

The Treasury Department’s Office of Foreign Assets Control (OFAC) took action last Monday, November 8, 2021, and sanctioned a Latvia-based exchange, Chatex, its associated support network, and two ransomware operators for...more

Bracewell LLP

OFAC Ransomware Update

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On Friday, OFAC published a compliance guide aimed at the virtual currency industry, which promotes sanctions compliance amid the rise of ransomware attacks. Similar to OFAC’s recent advisory, this compliance guide is yet...more

WilmerHale

DOJ Launches “Civil Cyber Fraud Initiative” to Use the False Claims Act to Address Cybersecurity-Related Conduct

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The US Department of Justice (DOJ) recently announced plans to use the False Claims Act (FCA) to pursue cybersecurity-related fraud by government contractors, subcontractors and grant recipients, including for providing...more

BCLP

Compliance Impact of FinCEN Statement of Priorities

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At the direction of the President, FinCEN is intensifying its regulation of banks and fintechs across the spectrum of the laws that it is charged with enforcing. This past June, the White House published the Memorandum on...more

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