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
What's the Tea in L&E? Employee Devices: What is #NSFW?
Preparing for a Government Healthcare Audit
Tackling Credit Push Fraud: Understanding Nacha's Risk Management Package (Part Two) — Payments Pros: The Payments Law Podcast
Compliance into The Weeds: The Complexity of Risk Assessments
Behavioral Health Compliance
The Importance of Assessment Areas
RegFi Episode 8: The Technological Path to Outcomes-Based Regulation with Matt Van Buskirk
What Physicians Need to Understand About Balance Billing
What Nonprofit Board Leadership Needs To Know About Internal Investigations
Taking a Behavioral Approach to Compliance
Episode 291 -- Interview of Mary Shirley on Her New Compliance Book
ChatGPT Risks for Compliance Programs
Season 2 Episode 3 - The Role of Ethics and Compliance Programs in International Business
In the Boardroom With Resnick and Fuller - Episode 4
What Non-Financial Institutions Need to Know About Gramm-Leach-Bliley
"Board-er" Patrol in Privacy and Cyberattacks - Unauthorized Access Podcast
On August 1, 2024, the US Department of Justice (DOJ) Criminal Division introduced its Corporate Whistleblower Awards Pilot Program (Program), which, like a modern-day Western posse, aims to bring justice to the wild frontier...more
Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more
Federal law enforcement agencies, including the U.S. Drug Enforcement Administration (DEA), have amped up their investigations into the drug ketamine in recent years, likely in reaction to some high-profile overdose deaths....more
It may seem like a Herculean task — but it can be done. I regularly opine that mitigating sanctions risks for your third-party population is an easier task than doing so for your anti-corruption risks. One big reason —...more
On April 22, 2024, the Acting Assistant Attorney General for the Department of Justice (“DOJ”) Criminal Division (“Acting AAG”) Nicole M. Argentieri offered commentary in a blog post regarding the Criminal Division’s newest...more
Could you provide an insight into recent trends shaping financial crime in your country of focus? How great a risk does money laundering in particular now pose to companies? One would likely never imagine compliance as...more
In early October 2023, Deputy Attorney General (DAG) Lisa Monaco announced a “new” (but not new) Department of Justice (DoJ) policy intended to incentivize acquiring companies to voluntarily self-disclose criminal misconduct...more
One cannot really say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program should be based on a risk assessment, on an understanding of your...more
Significant Expansion to Corporate Criminal Liability Becomes Law in the United Kingdom - On 26 October 2023, the Economic Crime and Corporate Transparency Act (the Act) became law. Under the Act, corporations will become...more
Welcome to EO Radio Show – Your Nonprofit Legal Resource. I'm Cynthia Rowland, and today, we'll cover an important governance topic for all nonprofit organizations. That is, what leadership needs to know about internal...more
Call me a skeptic. Call me cynical. I understand that the International Organization for Standardization (ISO) provides valuable standardization services and guidance. The ISO is comprised of 169 member countries....more
No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more
In the realm of auditors intersecting compliance and fraud risk audits, a fierce battle of perspectives rages on. Compliance professionals yearn for a bigger role, a seat at the table to tackle potential compliance...more
It is no great secret that criminal enforcement in the United Kingdom against corporations has lagged behind our counterparts in the United States and other jurisdictions. In recent years the UK government has introduced a...more
Even with the current focus on sanctions compliance, many companies have done little to assess and enhance their existing sanctions compliance program. Instead, a number of companies have stitched together a basic sanctions...more
Let’s move beyond the headline – trade compliance is the new FCPA. We get it. The next step is to do something about it. The Justice Department has repeated this refrain – it is one of its greatest hits. In addition, DOJ,...more
Companies have to demand a new focus from their CEOs, senior executives and legal compliance team in response to the new DOJ and regulatory initiatives. These steps are not just suggestions nor items that can be prioritized...more
On March 3, 2023, as part of the rollout of several updates to its guidance on corporate compliance programs, the Department of Justice (DOJ) released a new policy aimed at incentivizing compliance-driven compensation and...more
I always enjoy pulling out the crystal ball and looking forward with due consideration of last year’s trends. It is a perspective that gives us all the opportunity to identify important trends and to set an agenda for the...more
The DOJ has signaled that CEO and CCO certifications will become a staple of all corporate settlement agreements. Critics worry CEOs and CCOs face undue personal liability and argue it will dissuade CCOs from accepting the...more
Corporate compliance professionals can learn a lot from the audit world. Our latest lesson comes in a statement from the Securities and Exchange Commission, warning auditors to do better at identifying the risk of fraud among...more
Chief compliance officers rely on several important sources for feedback — internal data and communications (reviews with board, senior managers, employees); and benchmarking against comparable organizations. An internal...more
When the tide goes out, as it appears to be doing now with the market down 20% percent from its highs in January, bad actors will be left exposed for everyone to see. Simply put, as the market drops those companies hiding...more
Chief compliance officers have plenty of things to do and risks to manage. CCOs have a unique remit and a set of skills that should be applied whenever needed. While I am not trying to increase CCO workload (and forgive me...more
In one of the first substantive speeches on corporate criminal enforcement under the Biden administration, Deputy Attorney General Lisa Monaco announced on October 28, 2021, several immediate changes to Department of Justice...more