News & Analysis as of

Policies and Procedures Compliance Penalties

Holland & Hart LLP

The Corporate Transparency Act Compliance Deadline Looms—Lenders, Are Your Customers Ready? Are YOU Ready?

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The January 1, 2025, deadline imposed by the Corporate Transparency Act (CTA) for all “reporting companies” formed prior to 2024 to file their initial beneficial ownership reports with FinCEN is rapidly approaching. Given the...more

Lippes Mathias LLP

Hospital Administrators – Is Your Hospital Cyber-Secure?

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On October 2, 2024, New York adopted new regulations requiring general hospitals to implement heightened cybersecurity safeguards. General hospitals, as defined in Article 28 of the NY Public Health Law, generally must begin...more

Walkers

Obligation for independent AML Audits under the Anti Money Laundering Regulations – What you need to know

Walkers on

Conducting an independent AML audit at a frequency based on the nature, scale and complexity of the entity is a requirement under the AML Regulations. AML audits are an important component of the control environment to...more

Seward & Kissel LLP

Continued SEC Enforcement Actions Relating to Off Channel Communications

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Who may be interested: Registered Investment Advisers, Registered Investment Companies, Compliance Staff - Quick Take: The SEC recently announced a number of additional enforcement actions relating to recordkeeping...more

Guidepost Solutions LLC

DOJ Has Issued New Compliance Guidance. Now What?

On September 23, 2024, the U.S. Department of Justice (“DOJ”) released updates to its Evaluation of Corporate Compliance Programs (“ECCP”) guidance. In a move that surprised no one (especially if companies have been reading...more

Society of Corporate Compliance and Ethics...

How a code of conduct reflects culture and meets DOJ requirements

Every compliance program begins with a code of conduct. The code of conduct expresses a company’s fundamental values and its commitment to living by them. Although a code of conduct is usually a very high-level document, it...more

Guidepost Solutions LLC

Mandatory Reporting: Essential Insights for Child-Centric Organizations

For institutions and organizations entrusted with the care of children, such as schools, daycares, hospitals, faith-based communities, camps and sports teams, the responsibility to safeguard their well-being is vital....more

Proskauer - California Employment Law

PAGA 2.0 – What Employers Need to Know As PAGA Reform Becomes Law

On June 27, 2024, by near-unanimous vote, the California Legislature passed two bills enacting much-needed reform to the Private Attorneys General Act (PAGA). We previously reported on the legislative compromise last week,...more

Mintz - Employment Viewpoints

A New Dawn (Maybe) for California Employers: State and Business Groups Strike Deal on PAGA Reform

On June 18, 2024, Governor Newsom, in collaboration with legislative leaders, unveiled a landmark agreement to reform the Private Attorneys General Act (PAGA). The agreement comes before California voters could weigh in on...more

Hinch Newman LLP

Leading FTC Defense Lawyer on Agency Consumer Protection Investigation Procedures

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Generally speaking, investigatory procedures, including use of compulsory process, may be used by Federal Trade Commission (FTC) attorneys in connection with the spectrum of activities that the agency is authorized or...more

ArentFox Schiff

Impending Deadline for Forced and Child Labor Reporting: International Mining Companies Should Immediately Assess their Reporting...

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Mining companies operate in many countries where the risks related to the presence in the supply chain of forced and child labor tend to be high. If these companies also carry on certain business activities in Canada...more

American Conference Institute (ACI)

U.K. Parliament Giving Whistleblower Protections a Fresh Review

Recent legislative developments in the United Kingdom, public remarks from the new director of the UK Serious Fraud Office (SFO), and recent parliamentary hearings on the Post Office Horizon scandal put a spotlight on...more

King & Spalding

Executive Order Establishes New Outbound Investment Screening Program

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Prohibitions targeted to prevent China’s exploitation of dual-use technology - On August 9, 2023, President Biden signed a historic Executive Order on Addressing United States Investments in Certain National Security...more

Guidepost Solutions LLC

Compliance Experts Discuss Off-Channel Communications and Mobile Surveillance Policies

Roundtable Discussion: Off-Channel Communications and Mobile Surveillance Policies - Surveillance, monitoring, escalation, and reporting are critical components to regulatory compliance and risk management. So is...more

K2 Integrity

Construction Safety: How Robust Compliance Programs Can Ensure Worker Safety

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With construction less impacted by the COVID-19 pandemic, and with a large number of projects in progress across the country, the industry is seeing a rebound in construction activity. This increase in activity, however,...more

Seward & Kissel LLP

SEC Charges Sixteen Firms for Recordkeeping Failures Related to Employee Use of Personal Devices

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On September 27, 2022, the Securities and Exchange Commission (“Commission”) entered into a series of settled orders (“Orders”) against 15 broker-dealers and one affiliated investment adviser for widespread failures by the...more

Faegre Drinker Biddle & Reath LLP

16 “At One Blow” – The SEC Sanctions for Recordkeeping Failures

On September 27, 2022, the SEC announced that it had sanctioned 15 Broker-Dealers and one affiliated RIA for widespread recordkeeping violations of Section 17(a)(1) of the Exchange Act and Rule 17a-4(b)(4) thereunder...more

Foley Hoag LLP

SEC Brings First Enforcement Action Against Issuer for Disclosures About Financial Effects of COVID-19

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On December 4, 2020, the SEC brought its first case charging a public company, The Cheesecake Factory, with making misleading disclosures about the effects of COVID-19 on its business operations and financial condition. The...more

Thomas Fox - Compliance Evangelist

Embraer FCPA Enforcement Action – Part III

Today I continue my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the...more

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