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
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
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
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
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 guidance outlines principles and key considerations for banking organizations as they navigate risks associated with third parties, including fintechs. On June 6, 2023, the Federal Deposit Insurance Corporation...more
Agencies Issue Final Guidance on Third-Party Risk Management - On June 6, the Federal Reserve, FDIC, and OCC issued final joint guidance (the Guidance) pertaining to banking organizations’ risk management of third-party...more
Financial technology companies (fintechs) and other third parties in bank partnerships are routinely subject to scrutiny by their banking partner customers. The Federal Reserve System, the Federal Deposit Insurance...more
Sustainable social development is increasingly viewed as critical to ensure the future stability of the global economy and planet. This often-overlooked element of the ESG (Environmental, Social, and Governance) agenda is...more
On July 13, the Federal Reserve, FDIC, and OCC proposed risk management guidance to help banking organizations manage risks related to third-party relationships, including relationships with vendors, FinTech companies,...more
When risk is stranger than fiction - While this might seem a fictitious depiction of how strategy and action gain momentum and approval within an organization, I promise you: It’s not farfetched. Anyone who’s had a few years...more
On March 5, 2020, the OCC issued a revised set of FAQs designed to supplement OCC Bulletin 2013-29 (Third-Party Relationships: Risk Management Guidance) issued on October 30, 2013. ...more
At the end of December, China acknowledged the existence of the coronavirus, and this burgeoning heath crisis is becoming a supply chain problem. China, a major manufacturing hub for materials, products and components being...more
Now in its third month, the coronavirus outbreak that began in Wuhan, China, has claimed over 2,000 lives and brought one of the world’s most dynamic economies to a near standstill. ...more
Amazon.com has become ubiquitous in online retail, dominating the e-commerce marketplace worldwide. For sellers, Amazon acts as a crucial means of reaching customers around the globe. For consumers, it has become an...more
Believe it or not, but companies are still struggling with third-party risk management systems. I know this sounds hyper-critical but many companies continue to hang onto paper due diligence systems (sometimes with or...more
If you do not manage the third-party relationship it can all go downhill very quickly and you might find yourself with a potential FCPA violation. Now the DOJ has explicitly adopted this approach as a key determination of...more
The first lesson for the compliance practitioner is that you should actually test your compliance program in high-risk/high-profile situations. The unfurling team likely did practice their unfurling regime but apparently...more
On October 20, 2017, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2017-43 (the “Bulletin”) outlining principles that OCC-supervised banks should follow to prudently manage the risks associated with...more
On June 7, the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2017-21 (Frequently Asked Questions to Supplement Bulletin 2013-29; Third-Party Relationships: Risk Management Guidance). This is the OCC’s...more
Financial Industry Developments - Federal Reserve Board Approves Extended Transition Period for Deutsche Bank AG, SVB Financial Group, and UBS Group AG to Conform Investments in Certain "Illiquid Funds" to Requirements of...more
The Office of the Comptroller of the Currency has issued a new bulletin (2017-21) containing fourteen frequently asked questions to supplement OCC Bulletin 2013-29 entitled “Third-Party Relationships: Risk Management...more
Today, I continue my exploration of Level III, deep dive due diligence, by discussing how this should be considered for third parties. I am joined this week by Candice Tal, founder and Chief Executive Officer (CEO) of...more