We are halfway through 2024, which means: now is the perfect time to evaluate your 2024 compliance initiatives and assess how you’re doing! It’s time to give your compliance work plan a 6-month check-up....more
Is your organization’s culture complimenting your healthcare compliance program? Does it enhance and maximize your program’s effectiveness? Or, is your culture secretly sabotaging your compliance efforts?...more
Board Oversight of the Compliance Program - The GCPG cross-references the US Sentencing Guidelines board responsibility requirements of the organization’s compliance program, and provides that the board shall “be...more
In the previous three newsletters, the authors reported about the recent challenges associated with the field moving towards a quasi-legal system. Yet, something we did not expand upon is how Title IX officers are coping with...more
Self-Reporting Remains a Major Focus - Few executives expect to interact with the Department of Justice (DOJ) during their careers, but the current DOJ has given companies some homework, and the assignment applies to...more
To say it’s a challenge might be an understatement: Many managers are wondering to what extent their regulators will allow them to modify compliance standards during COVID-19....more
On June 1, 2020, the U.S. Department of Justice (DOJ), Criminal Division, updated its guidance on the “Evaluation of Corporate Compliance Programs,” providing increased clarity on some of the key questions prosecutors will...more
A risk alert issued on November 7, 2019, by the SEC’s Office of Compliance Inspections and Examinations underscores a continuing dilemma faced by SEC-regulated entities....more
Litigation Risks Posed by the SEC’s Regulation Best Interest - Pete Tepley and Meredith Lees highlight litigation risks posed by the SEC’s Regulation Best Interest (Reg-BI), litigation risks that may arise from Reg-BI’s...more
As we previously reported, effective immediately, school districts must comply with ISBE emergency rules for the use of seclusion and restraint....more
OFAC (Oficina de Control de Activos Extranjeros) es un departamento del Tesoro de los Estados Unidos que administra y aplica sanciones económicas y comerciales basadas en la política exterior de los Estados Unidos y los...more
OFAC (Office of Foreign Assets Control) is a department of the US Treasury that administers and enforces economic and trade sanctions based on US foreign policy and national security goals. ...more
Over the summer, EPA published a policy document to enhance cooperation between it and the many state agencies that enforce federal environmental programs. ...more
On July 11, 2019, the Antitrust Division of the United States Department of Justice announced a key policy change that now permits the Division to consider the existence and efficacy of corporate compliance programs in its...more
On June 19, 2019, a group of natural gas and power trade associations filed a white paper with the Federal Energy Regulatory Commission (FERC) calling for more transparent and efficient enforcement investigations by the...more
The communication of policies and procedures to employees by disseminating publications that explain in a practical manner what is required is considered the cornerstone of an effective compliance program and...more
In our last alert, we discussed the first three fundamental categories of an effective compliance program: (1) Risk Assessment; (2) Management Buy-in; and (3) Code of Conduct [see our previous alert for the full discussion ...more
Seyfarth Synopsis: Compliance with industry standard for combustible dust set for September 2020. Don’t delay, because OSHA is already citing employers using the not yet effective NFPA 652, Standard on the Fundamentals of...more
The rules and regulations governing private equity and hedge fund advisers continue to develop in response to changes in technology, particularly in the areas of social media and cybersecurity. As a result, advisers become...more
When the European Union’s General Data Protection Regulation (GDPR) became effective on May 25, 2018, many US-based hospitals struggled to determine whether they were subject to the GDPR and, if so, what they must do to...more
The BCPB has historically taken the position that it can use investigations to conduct compliance “sweeps” of entire industries. Indeed, a version of the BCFP’s Enforcement Policies and Procedures Manual made available to the...more
Yesterday I introduced, with the help of the Red Baron, the topic of a Compliance Center of Excellence (CCoE). Today I want to expand out into how a Chief Compliance Officer (CCO) or compliance practitioner would design a...more
Today I consider some tips from the world of fiction composition for your compliance program. These lessons are applicable for both the design, enhancement and implementation of your compliance regime. Moreover, by...more
The Department of Health and Human Services, Office of Inspector General (OIG), in conjunction with the Health Care Compliance Association, recently released a resource document to help healthcare organizations measure the...more
In the 1990s, as part of the Federal Sentencing Guidelines, the U.S. Sentencing Commission developed for the first time the criteria upon which it will view an organization’s compliance program to be “effective.” In October...more