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Enforcement Internal Controls

Foley & Lardner LLP

Down But Not Out: Federal Court Curbs SEC Cybersecurity Enforcement Authority

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In a stinging rebuke of its attempted cybersecurity-related enforcement against a public company, a federal judge recently dismissed most of the charges that the U.S. Securities and Exchange Commission (SEC) had filed against...more

Society of Corporate Compliance and Ethics...

For better or for worse: Is your (non) compliance contagious?

Wouldn’t you like your compliance program to be as infectious, contagious, and as long-lasting as COVID-19? Forgive the analogy, but every compliance officer aspires to see their diligent efforts in establishing and...more

Health Care Compliance Association (HCCA)

Explore the how and the why

Anytime a compliance violation occurs—or even a breakdown in compliance controls that doesn’t ultimately result in noncompliance—the remediation process takes center stage. And this is where questions of how and why are...more

Holland & Knight LLP

Aumentan las sanciones por incumplimiento del SAGRILAFT y PTEE en empresas Colombianas

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Dada la relevancia que actualmente está obteniendo la prevención de los riesgos y el cumplimiento normativo en el desarrollo de los negocios, la Delegatura de Asuntos Contables y Económicos de la Superintendencia de...more

NAVEX

You Don’t Need New Regulation to Have AI Enforcement Risk

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One year ago, compliance officers began 2023 dazzled by the potential of artificial intelligence, and braced for new regulations to govern how corporate organizations use AI. Then a funny thing happened: governments didn’t...more

Hudson Cook, LLP

New York DFS Finalizes Amendments to Cybersecurity Regulations

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On November 1, 2023 the New York Department of Financial Services ("DFS") released amended cybersecurity regulations ("Regulations"). These changes will impose additional controls, demand more frequent risk assessments, and...more

White & Case LLP

The SEC’s Charges Against SolarWinds and its Chief Information Security Officer Provide Important Cybersecurity Lessons for Public...

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On October 30, 2023, the US Securities and Exchange Commission ("SEC") announced that it filed charges against SolarWinds Corp. ("SolarWinds" or the "Company") and its Chief Information Security Officer ("CISO") in connection...more

Holland & Knight LLP

New Financial Responsibility Requirements from U.S. Department of Education

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The U.S. Department of Education (Department) has identified college closures and institutional financial instability as creating significant costs for students and taxpayers. From 2013 to 2022, the Department sought more...more

Morrison & Foerster LLP

A New Frontier for SEC Cybersecurity Enforcement? The SEC Charges SolarWinds and its CISO with Securities Fraud

Earlier this week, the SEC accused SolarWinds Corporation (“SolarWinds” or the “Company”) and its Chief Information Security Officer (“CISO”) of committing scienter-based securities fraud, among other violations, for...more

Society of Corporate Compliance and Ethics...

[Virtual Event] ESG and Compliance Conference - June 28th, 8:25 am - 4:30 pm CT

Achieve your ESG goals in 2023 - Environment, Social, and Governance (ESG) is a top priority for organizations of all types and sizes, and it the compliance team is a key factor in the ESG equation. Much like regulatory...more

Holland & Knight LLP

Risky Business: SEC Expands DCP Enforcement Using Company Risk Factors

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Outside of the small circle of federal securities law nerds (we proudly proclaim our membership), the phrase "disclosure controls and procedures" (DCP) rarely garners much attention. However, a recent settled order issued by...more

Morrison & Foerster LLP

SEC Action Against Cheetah Mobile Execs Shows Rule 10b5-1 Plans Are Not a Get Out of Jail Free Card

On September 21, 2022, the Securities & Exchange Commission announced a settled enforcement action against two executives of China-based mobile internet company Cheetah Mobile, Inc. The SEC alleged that Sheng Fu, Cheetah...more

Troutman Pepper

New DOJ Guidance Tightens Corporate Enforcement Strategy

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Join Troutman Pepper White Collar and Government Investigation Partners Callan Stein, Miranda Hooker, and Allison DeLaurentis for a podcast discussion on the DOJ’s updated guidelines regarding corporate criminal enforcement....more

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - July 21st - 22nd, Boston, MA

ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...more

NAVEX

DOJ Commentary on Corporate Compliance and Enforcement: What You Need to Know

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Recently, Assistant Attorney General, Kenneth A. Polite Jr. delivered remarks at Compliance Week detailing how the DOJ evaluates corporate compliance programs. The purpose of clearly stating these expectations in detail is...more

Bass, Berry & Sims PLC

OFAC Enforcement Update: Settlements Show Value of Internal Controls, Disclosure

Bass, Berry & Sims PLC on

On December 23, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and TD Bank, N.A. (TD) reached a settlement to resolve TD’s violations of the North Korea Sanctions Regulations and the...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

[Webinar] Privacy, Data and Cyber Security: The Current Legal Landscape - November 11th, 12:00 pm - 1:00 pm EST

Companies and consumers alike are under perpetual assault from bad actors as IoT, work from home, and cloud migration – all intended to improve productivity – have expanded the cyber attack surface. The continually evolving...more

Womble Bond Dickinson

Administration's Anti-Corruption Efforts Likely to Yield Greater FCPA Enforcement in Latin America and Beyond

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On June 3 of this year, the Biden Administration made plain its commitment to fighting corruption around the world, releasing a document identifying the fight against corruption “as an economic and national security priority”...more

BCLP

Anti-Money Laundering Continues to be Among the Highest Regulatory Priorities, As Evidenced by Recent Enforcement Cases and...

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For the past decade, anti-money laundering (“AML”) has been at the forefront of securities regulators’ priorities.  Indeed, AML enforcement cases have resulted in some of the highest fines imposed by securities regulators,...more

WilmerHale

Bribery Act 2010: Ten Years On

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Ten years have passed since the introduction of the UK’s primary anti-corruption law, the Bribery Act 2010 (“the Act”). This article examines the extent to which the Act has lived up to its billing as the international “gold...more

Troutman Pepper

Managing Your Next Examination - You Got This

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Bank examinations, holding company inspections and other “supervisory events” can be a source of anxiety and dread for those who work in the banking industry. Originally published in ABA Bank Compliance - March/April 2020....more

Latham & Watkins LLP

Current Developments in the US: White-Collar Enforcement and trends for 2020

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In the following article we will discuss the current developments and trends for 2020 and outline what EU-based companies with a US presence should look out for in 2020 regarding US white-collar and compliance trends in the...more

Dorsey & Whitney LLP

OFAC Issues Sanctions Guidance and the Concept of Culture Gains Traction (With Chinese Translation)

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On May 2, 2019, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)—the U.S. agency tasked with administering and enforcing the U.S.’s economic and trade sanctions programs—published A Framework for...more

Dorsey & Whitney LLP

OFAC Issues Sanctions Guidance and the Concept of Culture Gains Traction

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On May 2, 2019, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)—the U.S. agency tasked with administering and enforcing the U.S.’s economic and trade sanctions programs—published A Framework for...more

Eversheds Sutherland (US) LLP

Recent guidance brings OFAC in line with domestic and global compliance trends

On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more

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