To what extent are boards and senior executives in your country of focus taking proactive steps to reduce incidences of fraud and corruption from surfacing within their company? Over the past several years, there has been...more
The Department of Justice (DOJ) has unveiled a new whistleblower policy designed to incentivize individuals to disclose corporate misconduct through financial rewards from any resulting forfeiture of criminal proceeds. The...more
The EPA intends to increase its review of voluntary self-disclosures of violations submitted electronically under EPA’s Audit Policy. The EPA Office of Inspector General (OIG) recently issued a report detailing the results of...more
Key Takeaways - As DOJ senior leadership signaled it would do since March, DOJ has now officially required as part of resolving a corporate enforcement action, that a Chief Compliance Officer (CCO) and Chief Executive...more
On April 9, 2021, the federal banking regulatory agencies (the Federal Reserve, FDIC and OCC) together with FinCEN and the National Credit Union Administration issued a joint statement addressing how risk management...more
However, too often the focus on GRC technology is limited to the process management of forms, workflow, tasks, and reporting. These are critical and important elements, but the role of technology for GRC is so much broader to...more
In June 2020, the US Department of Justice Criminal Division (DOJ) released an updated “Evaluation of Corporate Compliance Programs” notification. Our (and maybe your) first reaction upon hearing of this doctrine was likely,...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
There may never have been a situation quite like the one businesses find themselves in right now, as the COVID-19 pandemic creates an unprecedented range of challenges. Those will demand unprecedented and proactive solutions...more
In the Care Alternatives False Claims Act (FCA) appeal, a panel of the US Court of Appeals for the Third Circuit on March 4 reversed the summary judgment granted to hospice provider Care Alternatives at the district court,...more
Federal construction contractors are barred from discriminating in employment on the basis of race, color, religion, sex, sexual orientation, gender identity, national origin, disability, or covered veteran status, and many...more
Compliance officers face almost an infinite number of risks – not to be trite, but CCOs can drive themselves crazy identifying every plausible legal and compliance risk a company faces. I am exaggerating a little bit to make...more
Moving on, 2019 was a big year in OFAC compliance. The Sanctions Compliance Guidance was a major change in sanctions compliance. OFAC has set high expectations for compliance. Whether companies have received and responded to...more
The parallels with compliance management - Think about it: The challenges you face in managing your compliance obligations aren’t unlike bringing the family together for the holiday meal…you have to round everybody up,...more
Under Russian Data Protection Law, when collecting personal data, data operators (controllers) must ensure that recording, systematization, accumulation, storage, updating and extraction of personal data relating to Russian...more
As we previously reported, effective immediately, school districts must comply with ISBE emergency rules for the use of seclusion and restraint....more
On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more
Let’s consider a list of 20 questions to reflect the oversight role of directors. These are questions the Board should ask of both senior management and the Board itself. The questions are not intended to be an exact...more
The California Consumer Privacy Act (CCPA) imposes a broad array of new legal obligations on businesses to inform consumers about the categories of personal information being collected online and how it will be used....more
What do people see when they look at a piece of fine art—such as a painting by Cezanne, a sculpture by Giacometti, or a three-dimensional combine by Rauschenberg? To a great extent, it depends on who’s doing the looking. An...more
As we sip champagne reflecting on the first anniversary of the effective date of the European General Data Protection Regulation (GDPR), we consider the obligations that employers should bear in mind....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
How is the #MeToo movement driving demand for greater personal accountability from both workers and management?...more
All employers with even a single employee working in New York City or New York State will be required to meet requirements designed to address sexual harassment under new city and state laws....more
On August 10, 2018, the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) issued a new directive, 2018-04, announcing a plan to implement focused reviews of contractors’ compliance with Executive...more