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
On this episode of Culture & Compliance Chronicles, Amanda Raad and Nitish Upadhyaya from Ropes & Gray’s Insights Lab, and Richard Bistrong of Front-Line Anti-Bribery, are joined by Danny Mayhew, the global head of...more
Leveraging advanced technologies like artificial intelligence (AI) is no longer a luxury; it is quickly becoming necessary. For compliance professionals, AI offers a transformative tool to enhance program efficiency, improve...more
We distil key practical takeaways from the UK Government’s official guidance on the corporate criminal offence of failure to prevent fraud (the Guidance). Businesses and compliance teams will be working to review and...more
The UK Government has finally published its official guidance on the corporate criminal offence of failure to prevent fraud (the Guidance). The offence will come into force on 1 September 2025. By then, businesses that fall...more
On 6 November 2024, the UK Government published the much-anticipated guidance on the new corporate offence of failure to prevent fraud (the “Guidance”). The failure to prevent fraud offence forms part of a huge shift in the...more
Deux études particulièrement intéressantes ont récemment été publiées par l’Agence Française Anticorruption (l’AFA) et la Commission européenne dans le domaine de la lutte contre la corruption. La première étude publié...more
INTRODUCTION - On 26 October 2023, the UK Economic Crime and Corporate Transparency Act 2023 (the "Act") received royal assent and became law. The Act introduces a new strict liability corporate criminal offence of failure...more
Deputy Assistant Attorney General Nicole M. Argentieri’s speech highlighted a critical shift in the Department of Justice’s (DOJ) approach to evaluating corporate compliance programs. As outlined in the updated 2024...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
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
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
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
Earlier this month, the Criminal Division of the United States Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs guidance. In considering enforcement actions against companies, prosecutors...more
The Situation: The Department of Justice ("DOJ") has updated its "Evaluation of Corporate Compliance Programs" guidance for prosecutors. The Result: The updates provide additional insights into the factors the DOJ is...more
The US Department of Justice’s (DOJ’s) Criminal Division published an update on June 1 to its Evaluation of Corporate Compliance Programs guidance, which is used by its prosecutors to assess the adequacy and effectiveness of...more
With a new year, many folks have been promoted to the CCO chair. What should be your plan starting the new year and a new job. The answer is found in the eBook Compliance Program Game Plan by myself and Jonathan Marks. ...more
From the HR and compliance perspective, there are four steps to undertaking a gap analysis: 1) understanding the compliance and HR environment in your organization; 2) taking a holistic approach to understanding the...more
Last week, I penned a blog series around a special White-Collar Crime section in the July Harvard Business Review (HBR). This week, I propose to write a multipart blog post series based upon the MIT Sloan Management Review...more
Next week I embark on a five-part podcast series sponsored by Hanzo. In the series we will consider how to leverage Artificial Intelligence (AI) in compliance investigations. ...more
This is my favorite topic. New trends come and go in the compliance field, while effective solutions and strategies slowly but surely take hold. Eventually, an effective compliance practice or strategy becomes a “best...more
A fully operationalized compliance program should invite a variety of responses. Just as all risks are different, the management of risks can be handled differently. ...more
In this multi-part blog post series, I am exploring the increased use of technology to continue to drive the performance of corporate compliance programs. I am considering the use of Artificial Intelligence (AI) in a best...more