Chatbots, Trust and Helplines
Culture Crafters - Ethics Culture Divide, Part 2 - Enhancing Corporate Culture: The Vital Role of Ethics in Talent Retention and Acquisition
Popcorn and Compliance: Episode 2 - Dracula’s Compliance Secrets: What Lurks in the Night
Control of a Set-aside Entity
FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA
Polsinelli Podcast - An International Trade Issue That May Impact Your Business
Protecting IP Through Employment Law
FCPA Compliance and Ethics Report-Episode 91, Internal Controls for Third Parties Under the FCPA, Part II
FCPA Compliance and Ethics Report-Episode 63-Managing the Third Party Relationship Under the FCPA, Part I
Recently, major media reported that a key financial services provider, SitusAMC, suffered a substantial data security incident. This Alert summarizes what we know so far, the possible legal implications, and some action items...more
On January 1, 2025, Illinois Public Act 103-0994 took effect, amending the Illinois Power of Attorney Act to reduce risk for third parties by ensuring the powers of attorney presented to them are still in force. The new law...more
Covered Entities should expect heightened supervisory focus on relationships where third party service providers (TPSPs) access systems or handle non-public information (NPI). On October 21, the New York State Department of...more
Employees may trust an AI chatbot more than they trust you, and that’s not necessarily a bad thing, if it leads to more reporting. In this podcast, Debbie Sabatini Hennelly, Founder & President of Resiliti shares that a...more
In this second episode in a 3-part series of podcasts, Tom Fox and Sam Silverstein discuss the critical divide in companies around Ethics and Culture. This series is based on data from a national survey of over a thousand...more
Welcome to a special series of Popcorn and Compliance. In this series, we will be looking at the Classic Universal Monster Movies from the 30s and 40s and mining them for compliance lessons. (Yes, it really is an excuse to...more
Recognizing the growing demand for virtual currency custodial services and the increased use of sub-custodial relationships in the digital asset space, the New York Department of Financial Services (NY DFS) announced updated...more
In the revised OpRes Guidance the Central Bank notes that there has been a gradual maturing of operational resilience frameworks within firms, industry shocks and ongoing change in financial services since the original OpRes...more
On August 21, a federal magistrate judge in the District Court for the Western District of Washington ordered a bank to produce certain records related to its prepaid debit card program, including documents maintained by...more
Recently, in a case titled Bivens v. Zep, Inc., the Sixth Circuit Court of Appeals ruled that an employer will only be liable for a customer's harassment of an employee when the employer intends for such harassment to occur....more
On August 5, the FDIC announced that banks it supervises can comply with Bank Secrecy Act (BSA) requirements to obtain identity information from new customers by using a pre-populated form, provided that the person opening...more
The Situation: The French Supreme Court recently considered whether a limitation of liability clause could be enforced against a third party to a contract claiming compensation for a breach of contract that caused it damage....more
The recent bank regulatory Joint Statement and request for information (RFI) on third-party deposit relationships and bank-fintech partnerships emphasize afresh regulators’ long-standing concern with financial institutions’...more
On July 25, 2024, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint statement to banks regarding risks...more
Last week, a bipartisan coalition of 30 state attorneys general (AG), led by Florida, Illinois, New York, and Texas, reached a settlement with Cameo — an online service that allows fans to pay for customized messages from...more
The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more
The federal banking regulators are seeking comment to better understand the relationship between financial institutions and third parties that work for them....more
Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more
Prior LLC Jungle posts have addressed the tricky issue of LLC managerial authority in the context of the LLC’s dealings with third parties... As referenced in those posts, under Corporations Code section 17703.01, when an...more
On May 3, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency (collectively, the agencies) released a guidebook aimed at assisting...more
“Third party” or “associational” retaliation is reprisal taken by an employer against someone other than the person who engaged in “protected conduct.” In 2011, the U.S. Supreme Court ruled that Title VII’s anti-retaliation...more
Welcome to the Fintech chapter of our annual report Consumer Financial Services 2023 Year in Review. Looking Ahead to 2024 - The CFPB is expected to finalize rulemaking authorizing supervision of payment application...more
In its Fall 2023 Semiannual Risk Perspective, published on December 7, the Office of the Comptroller of the Currency (“OCC”) reported on key issues facing the federal banking system. In evaluating the overall soundness of...more
The Albemarle FCPA enforcement action was announced at a good time. This year has been a slow year for DOJ’s FCPA enforcement program, although there are several months before the end of the year. The SEC, on the other hand,...more
Albemarle’s bribery schemes look and sound like text-book examples of third-party agents being paid high commissions as a way to funnel bribery payments to foreign officials at state-owned oil refineries. However, as usual,...more