News & Analysis as of

Policies and Procedures Fraud

Ropes & Gray LLP

[Podcast] Getting Your Head Around the UK’s New (and Globally Relevant) “Failure to Prevent Fraud” Offence

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On this Ropes & Gray podcast, join Amanda Raad, co-head of the firm’s global anti-corruption and international risk and crisis management & investigations practices, Nitish Upadhyaya, director of behavioral insights at the...more

Ankura

Remediation Happens: How To Identify, Mitigate and Resolve Related Risks

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Remediation occurs for a host of reasons. You may identify remediation risk from internal activities (e.g., an audit, a control break) or external activities (e.g., a complaint, a regulatory exam, a lawsuit). Sometimes a...more

Ankura

Identity Theft and How To Prevent It

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Imagine sitting in your living room, enjoying a cup of your favorite morning coffee, and you open your mail to discover that you recently opened a new bank account at XYZ Bank, unbeknownst to you. Or maybe you receive an...more

Rumberger | Kirk

FINRA Reminds Financial Firms How AI Use Poses Significant Risks

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These days, artificial intelligence is everywhere we look, and the financial services industry is no different. As AI use increases, regulatory bodies are updating their rules and guidelines detailing how companies should and...more

Walkers

Updates to the British Virgin Islands Anti-Money Laundering regime and changes for MLROs

Walkers on

Prior regulatory approval is now required for MLRO appointments – previously it was a notification requirement that had to be submitted within 14 days of the MLRO appointment. Firms in scope will now need to factor in...more

NAVEX

How Healthcare Organizations Can Strengthen Compliance to Fight Fraud, Waste and Abuse

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Healthcare organizations face an ever-growing list of regulatory demands and risks, with Fraud, Waste, and Abuse (FWA) at the forefront. Addressing FWA is more than avoiding fines under regulations like the False Claims Act –...more

Foley Hoag LLP - White Collar Law &...

Siemens Energy to Pay $104 Million Criminal Penalty for Misappropriating Competitor Bidding Information

On September 30, 2024, Siemens Energy Inc. (“Siemens Energy”)—a U.S.-based subsidiary of German manufacturing conglomerate Siemens Energy AG—pled guilty to federal criminal charges relating to the misappropriation of...more

Proskauer Rose LLP

SEC Enforcement Action Underscores Need for MNPI Policies in CLO Trading

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In a significant enforcement action, the SEC sanctioned a private fund manager for failing to establish and maintain adequate policies and procedures to prevent the misuse of material nonpublic information (MNPI) while...more

Mitratech Holdings, Inc

The State of Ethics Hotlines in 2024

Leveraging 40,000 anonymous ethics hotline reports and expansive customer interviews, Syntrio’s latest analysis uncovers trends in misconduct, reporting, and more...more

Awatif Mohammad Shoqi Advocates & Legal...

How Can Managers Be Lawfully Removed under the Commercial Companies Law in the UAE?

In the UAE, the process for lawfully removing a manager from a company is governed by Federal Decree-Law No. 32/2021 on Commercial Companies. This comprehensive legislation outlines the procedures and requirements for the...more

Proskauer - The Capital Commitment

Mid-Year Enforcement Update: SEC’s Continued Focus on Private Funds in 2024

As we reach the midpoint of 2024, the SEC has maintained its rigorous enforcement stance on the private funds industry, proposing new rules and oversight tools to better identify and investigate market practices. As 2024...more

Akin Gump Strauss Hauer & Feld LLP

Senate AI Working Group Releases Long-Anticipated Roadmap for AI Policy

On May 15, 2024, the Senate AI Working Group—Senate Majority Leader Chuck Schumer (D-NY) and Sens. Mike Rounds (R-SD), Todd Young (R-IN), and Martin Heinrich (D-NM)—issued their long-anticipated Roadmap for Artificial...more

Society of Corporate Compliance and Ethics...

[Virtual Event] ESG and Compliance Conference - June 18th, 8:00 am - 5:00 pm CT

Achieve your ESG goals in 2024 - 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

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Mintz

EnforceMintz — DOJ’s Continued Focus on Individual Accountability

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As discussed in EnforceMintz – Significant 2022 Regulatory and Policy Developments, the Department of Justice (DOJ) issued several memoranda in late 2022 and early 2023, reinforcing DOJ’s approach to individual accountability...more

Society of Corporate Compliance and Ethics...

Small things with big implications

I recently read about a banker being fired for inflating his expense report to the tune of a sandwich, some pasta, and a coffee. A judge ruled in the bank’s favor in a wrongful dismissal suit filed by the former employee. ...more

A&O Shearman

Top challenges for white collar crime and investigations lawyers in 2024

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We asked our global white collar crime team for their views on the key challenges in 2024 for in‑house investigations teams and white collar crime lawyers, and how to manage the associated risks. Here is what they said. ...more

Davis Wright Tremaine LLP

FINRA’s 2024 Annual Regulatory Oversight Report: Select Observations

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

Ankura

Navigating Uncharted Waters: Challenges and Considerations in Auditing the Ownership of Crypto Assets

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The rapid rise of crypto assets has presented both opportunities and challenges for auditors, with regulators, practitioners, and businesses grappling to establish clear guidelines and procedures. Even though there is no...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cyber Fraud Alleged by Former CIO for Purported Noncompliance With DoD Cyber Requirements

A recently unsealed case against Pennsylvania State University: - Serves as yet another example of the increased use of the False Claims Act (FCA) in cybersecurity enforcement. - Underscores the need for companies...more

ArentFox Schiff

2024 Examination Priorities for Investment Advisers from SEC Division of Examinations

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The US Securities and Exchange Commission (SEC) Division of Examinations recently released its 2024 Examinations Priorities, a yearly report that provides insight into the Division’s areas of focus to improve compliance,...more

StoneTurn

Can Understanding Insider Risk Help to Prevent Fraud?

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The UK government is moving towards introducing a new corporate criminal offence: Failure to Prevent Fraud and Money Laundering. The draft offence, contained in the Economic Crime and Corporate Transparency Bill, would hold...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - September 2023

Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more

Ankura

Failure to Prevent Fraud: Reasonable Procedures and Preparing Your Organization for the New Offense

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An amendment to the Economic Crime and Corporate Transparency Bill (the Bill) has brought in the offense of failure to prevent fraud (Offense). Under the new Offense, an organization will be liable where a specified fraud...more

HaystackID

[Webcast Transcript] M365 for Law Firms and Lawyers: Purview Premium eDiscovery and Security, Capabilities and War Stories

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Editor’s Note: In a rapidly evolving technological landscape, understanding the capabilities and limitations of platforms like Microsoft 365 (M365) is crucial for law firms, especially in the realms of eDiscovery and...more

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