Beyond the Bylaws: The Medical Staff Show | The Role of Bylaws in Medical Staff Governance, Part II
The Presumption of Innocence Podcast: Episode 60 - Enforcement Priorities of the Second Trump Administration: Employee Retention Tax Credit
Compliance Tip Of the Day: Using AI to Transform Whistleblower Response
Because That’s What Heroes Do: Deep Space 9 – Episode 30: Deep Trek Themes from Tacking into the Wind
FCPA Compliance Report: Amanda Carty on a Due Diligence and Risk Management
FCPA Compliance Report: Kristy Grant-Hart on A 360° Review of the Future of Compliance
Great Women in Compliance: Creating Space to Speak Up: The Story Behind Psst.org
Work This Way: A Labor & Employment Law Podcast | Episode 43: How Employers Can Navigate White Collar Crime with Erica Barnes & Christian Dysart of Maynard Nexsen
The Presumption of Innocence Podcast: Episode 59 - Enforcement Priorities of the Second Trump Administration: DOJ Focus
Creativity and Compliance: Bringing Joy to Compliance: A Conversation with Virginia MacSuibhne
Beyond the Bylaws: The Medical Staff Show - The Role of Bylaws in Medical Staff Governance, Part I
Compliance Tip of the Day: Embedded Compliance
Auditing Your Hotline and Case Management System
Compliance and AI: Ali Khan on Implementing AI Risk Management Systems
Compliance Tip of the Day: AI for Whistleblower Anonymity
Compliance Tip of the Day: Taming Complexity
Improving Your Code of Conduct
Envisioning a Compliant Workforce
Updating the Research Compliance Handbook
Investigations and Cognitive Interviews
As we bid farewell to 2024, we welcome not only another year but also several new disclosure requirements. In this Snapshot, we summarize several developments and best practices for public companies to consider as the 2024...more
This memorandum summarizes key U.S. Securities and Exchange Commission (“SEC”) and stock exchange regulatory filing deadlines, new disclosure requirements and general tips and guidance for both U.S. domestic issuers and for...more
In anticipation of the upcoming reporting season, this Update highlights some of the most significant rule changes, guidance, institutional investor areas of focus, and trends for public companies to consider while preparing...more
On October 22, 2024, the Securities and Exchange Commission (SEC) announced that it had charged four companies with making materially misleading disclosures regarding cybersecurity risks and intrusions, with one company also...more
On the heels of a $7.6 million payment by Cleveland Clinic to settle allegations of False Claims Act (FCA) violations and unallowable sharing of passwords, Michael Lauer, NIH deputy director for extramural research, penned a...more
Covered institutions will need to review their cybersecurity and incident response policies and procedures ahead of the applicable compliance deadline. ...more
Think of it as the compliance version of The Butterfly Effect – a small, unnoticed, action, or failure to act, somewhere in the organization that balloons over time into a much larger, material issue. Maybe an employee is...more
Earlier this month, the Financial Crimes Enforcement Network (FinCEN) continued its efforts to require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to take steps to prevent the laundering of...more
On March 13, 2024, Utah enacted the Utah Artificial Intelligence Policy Act (UAIP), which imposes certain disclosure requirements on entities using generative AI tools with their customers, and limits an entity’s ability to...more
Last year, the U.S. Securities and Exchange Commission (SEC) proposed ambitious rules relating to artificial intelligence (AI) that have drawn significant commentary and criticism. While it is unlikely that any changes in the...more
Like many other industries, Registered Investment Advisers ("RIAs") have dealt with significant regulatory, technological, and systemic change in recent years. Compared to FINRA-regulated entities, RIAs often face these...more
FINRA recently published its 90-page 2024 Annual Regulatory Oversight Report (Report) providing member firms with insight into six primary topics: Financial Crimes, Crypto Asset Development, Firm Operations, Communications...more
...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more
The growing concern around cyberthreats for companies across the nation is reflected in the increasingly crowded legislative landscape that provides guidance to organizations, employers, employees, consumers, and investors....more
Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents* I. Introduction - The SEC-registered investment adviser (“adviser”) population is large and diverse, ranging from global asset managers...more
Key Point: The decision making processes to determine whether a cybersecurity incident is material or not, should include documenting the factors behind each determination and should be practiced before an incident occurs. ...more
The SEC, by a 3-2 vote, has adopted new rules requiring companies to provide: ..current disclosure on Form 8-K within four business days of determining that a material cybersecurity incident has occurred; and ...more
In a narrow 3-2 decision on July 26, the SEC adopted its final rule concerning cybersecurity risk management, strategy, governance, and incident disclosure (the “Final Rule”). Below we highlight some of the principal changes...more
On July 26, 2023, the Securities and Exchange Commission (“SEC”) adopted final rules, rule amendments and form amendments to expand and standardize disclosures regarding cybersecurity risk management, strategy, governance,...more
The SEC’s Cybersecurity Proposals - The SEC has proposed four rules designed to address cybersecurity risk and management, including incident reporting by public companies....more
Last month, Gurbir Grewal, the Director of the SEC’s Division of Enforcement, spoke at the Financial Times Cyber Resilience Summit. During the remarks, he outlined the importance of cybersecurity and signaled that the SEC is...more
Based on updates to its rulemaking agenda that were released last week, the U.S. Securities and Exchange Commission (SEC) has delayed approval of two cybersecurity rules until at least October 2023. Both proposed rules were...more
At an open meeting on March 15, 2023, the U.S. Securities and Exchange Commission voted three to two to propose a new rule, form and amendments (together, “Proposed Rule”) and published an accompanying release (“Release”)...more
Given the increasing SEC scrutiny on disclosure practices in municipal finance, governmental issuers and conduit borrowers [e.g., 501(c)(3) corporations] are taking a fresh look at their disclosure policies and procedures,...more
Late last month the Securities and Exchange Commission (“SEC”) charged JP Morgan, UBS and Trade Station with violations of Regulation S-ID based on a range of inadequacies in their identity theft red flag policies and...more