Managing Sanctions Compliance
Regulatory Ramblings: Episode 68 - Why Geopolitical Risk Matters to Compliance and Legal Staff with Mark Nuttal and Chad Olsen
FCPA Compliance Report: Amanda Carty on a Due Diligence and Risk Management
Episode 364 -- Five Strategies to Mitigate a New Risk Environment
Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast
Compliance and AI: Ali Khan on Implementing AI Risk Management Systems
Compliance Tip of the Day: Superforecasting
Compliance Tip of the Day: The Last Mile
Key Takeaways From the OIG's New Compliance Guidance for Nursing Facilities — Assisted Living and the Law Podcast
Envisioning a Compliant Workforce
Updating the Research Compliance Handbook
The Election's Impact on the FTC Will Bring Big Changes, But Being Vigilant Must Remain a Priority
Navigating the NYDFS' Cybersecurity Guidance on AI — The Consumer Finance Podcast
The Future of AI Regulation and Legislation: 5 Key Takeaways
Investigations and Cognitive Interviews
Fraud Prevention Techniques for Nonprofit Organizations - Part 3
Steps Your Nonprofit Can Take to Mitigate Fraud Risks - Part 2
A Third Party's Perspective on Third Party Risk
Implications of the SEC Cybersecurity Disclosure Rule
Privacy Issues from Third-Party Website Tags
Publications & Advisories - November 2024 – Kathleen Benway, Jennifer Everett, Alysa Austin, and Kristen Bartolotta published “Federal Trade Commission’s Updated Health Breach Notification Rule Is Now in Effect” in Employee...more
On October 21, the Securities and Exchange Commission’s (SEC’s) Division of Examinations (Division) released its examination priorities for 2025, outlining the key topics the Division plans to focus on in the upcoming fiscal...more
On August 28, the Financial Crimes Enforcement Network (FinCEN) issued a final rule establishing anti-money laundering and countering the financing of terrorism (AML/CFT) compliance obligations for US Securities and Exchange...more
One of our recent posts discussed the uptick in AI risks reported in SEC filings, as analyzed by Arize AI. There, we highlighted the importance of strong governance for mitigating some of these risks, but we didn’t address...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Aug. 28, 2024, issued a final rule to help safeguard the investment adviser sector from illicit finance activity (Final Rule). The Final...more
Introduction - On 13 May 2024, the Securities and Exchange Commission (SEC) and the US Department of Treasury’s (DoT) Financial Crimes Enforcement Network (FinCEN) jointly proposed rulemaking to implement Section 326 of the...more
FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more
On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more
As of January 10, 2024, US securities exchanges may list Bitcoin ETFs for trading. Cryptocurrency enthusiasts hope this decision signals a broader adoption of cryptocurrency in the United States. Perhaps it does, but...more
Recent Department of Justice (“DOJ” or “Department”) activity on bribery in Mexico and Latin America sends a warning and provides a roadmap to companies doing business there. By following the roadmap, companies may escape...more
On November 27, 2023, the New York State Department of Financial Services (“DFS”) and First American Title Insurance Company (“First American”) entered into a consent order1 that resolved litigation over First American’s...more
Key Takeaways - With the SolarWinds enforcement action, the SEC continues to ratchet up its enforcement against companies that fail to properly disclose their cybersecurity incidents and risks. By naming the SolarWinds CISO...more
Swiss Banks Launch Tokenization Pilot, Crypto Custody and Trading Services - A recent press release announced a pilot by “SIX, the Swiss National Bank (SNB) and six commercial banks” that seeks “to test, in a live...more
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
SEC Adopts Final Rules on Cybersecurity Disclosures - The SEC has adopted rules requiring companies to provide disclosure within four business days of determining that a material cybersecurity incident has occurred, and...more
In July 2023, the PCAOB published the spotlight, “Staff Update and Preview of 2022 Inspection Observations.” The article summarized the PCAOB's common findings from its 2022 inspection season. Many of the findings observed in...more
Under the pressure of institutional investors, environmental groups, employees, consumers and other stakeholders, many companies have sought to demonstrate their bona fides when it comes to ESG through disclosure about their...more
Illinois Supreme Court Allows Massive Damages in Biometric Privacy Cases - “The case involves Ohio-based fast-food company White Castle.” Why this is important: Illinois has the strictest biometric privacy law in the...more
The SEC has nearly doubled the size of its Crypto Assets and Cyber Unit and has aggressively pursued cyber-related enforcement actions against public companies and regulated entities. In a few months the SEC will finalize...more
Crypto Apps Launch New Features, Custody Firm Achieves CCSS Certificate - According to recent reports, Uniswap V3 was the most used Ethereum contract in 2022, seeing over 15.5 million transactions throughout 2022 and using...more
Throughout 2022, we continue to see regulators placing an emphasis on the importance of protecting and securing information, in particular consumer personal information, at both the federal and state levels. ...more
According to the Cybersecurity & Infrastructure Security Agency, cybersecurity is the process whereby information and communications systems, and the information contained in those systems, are protected from and/or defended...more
A well-known digital currency investment services company announced the launch of its first European exchange-traded fund (ETF), according to a press release this week. The ETF, which will be traded on multiple foreign...more
On March 9, 2022, the U.S. Securities Exchange Commission (the Commission) announced proposed amendments to its rules regarding cybersecurity risk management, strategy, governance, and incident reporting by public companies...more
On February 9, the Securities and Exchange Commission (“SEC”) voted to propose rule 206(4)-9 under the Advisers Act and 38a-2 under the Investment Company Act (collectively, “Proposed Rule”). In general, the Proposed Rule...more