News & Analysis as of

Internal Controls Compliance

Fenwick & West LLP

The SEC is Cracking Down on Misleading Cybersecurity Disclosure

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On October 22, 2024, the SEC charged two current reporting companies, Unisys Corp. and Check Point Software Technologies, and two former public companies, Mimecast Limited and Avaya Holdings Corp., with making materially...more

Latham & Watkins LLP

Landmark Bank Secrecy Act Resolution Signals Increasing Focus on Banks’ Anti-Money Laundering Compliance

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Enforcement agencies urge investment in compliance programs. On October 10, 2024, the Department of Justice (DOJ) announced plea agreements with TD Bank N.A. (TDBNA) and its parent company, TD Bank US Holding Company...more

The Volkov Law Group

Episode 342 -- How to Conduct an Internal Compliance Site Visit and Review

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How can companies ensure that their compliance programs are robust enough to handle today’s complex ethical challenges? In this episode, Michael Volkov dives into the critical components of conducting an internal compliance...more

Thomas Fox - Compliance Evangelist

When New Business Risks Emerge: Lessons for Compliance from The Creature from the Black Lagoon

This week, leading up to Halloween, I will examine lessons for compliance professionals through the lens of the great Universal Movie Monsters: Frankenstein, Wolfman, Dracula, and The Mummy. Today, we consider what compliance...more

Fenwick & West LLP

Don’t Wait for the DOJ to Come Knocking: Important Whistleblower Protection and AI Risk Management Updates

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In September 2024, the DOJ’s Criminal Division released an updated Evaluation of Corporate Compliance Programs (ECCP) guidance document to address emerging risks. The ECCP serves as a roadmap for how DOJ evaluates a company’s...more

BCLP

DOJ Updates Criteria for Review of Corporate Compliance Programs, Emphasizing AI Issues

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On September 23, the Department of Justice updated the document it uses to evaluate a corporation’s compliance program in the context of wrongdoing by the corporation – the Evaluation of Corporate Compliance Programs, or...more

Foley & Lardner LLP

Five Compliance Best Practices for … Internal Controls and SOPs

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As an accompaniment to our biweekly series on “What Every Multinational Company Should Know About” various international trade, enforcement, and compliance topics, below find an update to our series on compliance checks that...more

Venable LLP

DOJ Revises Its Evaluation of Corporate Compliance Policy to Consider How Companies Address Risks Posed by AI

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The Department of Justice's Criminal Division is "using more tools than ever before to identify corporate misconduct and to encourage companies to be good corporate citizens," according to Nicole Argentieri, Principal Deputy...more

Benesch

DOJ Adds AI Considerations to Its Evaluation of Corporate Compliance Programs

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Last month, the U.S. Department of Justice’s (“DOJ”) Criminal Division announced its periodical update to its Evaluation of Corporate Compliance Programs (“ECCP”), zeroing in on how companies manage risk related to artificial...more

Troutman Pepper

Enhancing Compliance: The Power of Independent Monitorships in Consumer Protection — Regulatory Oversight Podcast

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In this episode of Regulatory Oversight, Ashley Taylor is joined by Vincent DiCianni, founder of Affiliated Monitors, and Kevin Lownds, deputy chief of the Medicaid Fraud Division at the Massachusetts Attorney General's...more

Thomas Fox - Compliance Evangelist

The 2024 ECCP – Using Data Analytics to Determine Employee Engagement, Trust, and Corporate Culture

In her recent speech at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. Principal Deputy Assistant Attorney General Nicole M. Argentieri spoke about the CWA and reviewed its early...more

Dorsey & Whitney LLP

DOJ Updates the Evaluation of Corporate Compliance Program Memorandum, Emphasizing Emerging Technologies, Data Analytics, and...

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On September 23, 2024, the U.S. Department of Justice (“DOJ”) released updates to its Evaluation of Corporate Compliance Programs policy (the “Updated ECCP”), building upon the March 2023 updates. Since 2017, DOJ has offered...more

Perkins Coie

FDIC’s Proposed Changes to Custodial Deposit Accounts: Practical Implications for Fintechs and Their Banks

Perkins Coie on

The Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking (the Proposal) on September 17, 2024, that seeks to strengthen recordkeeping for bank deposits held by nonbank companies on behalf of...more

Goodwin

FinCEN and Banking Agencies Propose AML Program Rule Updates for Banks and Other Financial Institutions

Goodwin on

Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more

The Volkov Law Group

John Deere Reaches $9.9 Million Settlement with SEC over FCPA Violations

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The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more

Thomas Fox - Compliance Evangelist

Looking Back on 9/11: John Lee Dumas – I Knew I Was Going to War

In 2021, I did remembrance of 9/11 with a podcast series and accompanying blog post series featuring the personal stories of persons in the compliance field with their thoughts about what the date of 9/11 meant to them, how...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Fundamentals of Compliance Investigations - December 16th - 17th, 8:00 am - 5:00 pm CT

Handle investigations with confidence - Effective compliance programs rely on effective investigators to follow up on reports and identify potential gaps that need attention. If you are a new or future investigator or are...more

Health Care Compliance Association (HCCA)

[Event] Healthcare Basic Compliance Academy - December 9th - 12th, San Diego, CA

Ideal for practitioners who want to build strong foundational knowledge of compliance program management in a healthcare setting and how to apply that knowledge in practice. Attendees will come away better prepared to...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance Risk Assessment and Management - November 13th - 14th, 8:00 am - 5:00 pm CT

Address risk proactively with effective risk assessments - Do you want to learn valuable strategies for identifying and mitigating risk in your organization—without the time and budget commitments of travel? This...more

Thomas Fox - Compliance Evangelist

Bank of America’s Corporate Culture Crisis: Part 5- A Case Study for Compliance

Compliance professionals constantly seek to understand how systemic issues within corporate hierarchies can lead to severe consequences. The recent revelations about Bank of America’s (BoA) persistent workplace culture...more

Health Care Compliance Association (HCCA)

[Event] Healthcare Basic Compliance Academy - November 18th - 21st, Boston, MA

Ideal for practitioners who want to build strong foundational knowledge of compliance program management in a healthcare setting and how to apply that knowledge in practice. Attendees will come away better prepared to...more

Holland & Knight LLP

DOJ Brings Suit Against University Under Its Civil Cyber-Fraud Initiative

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Late last week, the U.S. Department of Justice (DOJ) filed its complaint-in-intervention in a qui tam lawsuit against the Georgia Institute of Technology (Georgia Tech), alleging that the university failed to meet certain...more

Thomas Fox - Compliance Evangelist

Bank of America’s Corporate Culture Crisis: Part 3-The Role of Internal Controls

Compliance professionals constantly seek to understand how systemic issues within corporate hierarchies can lead to severe consequences. The recent revelations about Bank of America’s (BoA) persistent workplace culture...more

Goodwin

Supervisory Experience and Enforcement Actions Continue to Drive Supervisory Priorities and Policy Development

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This article identifies themes we have observed in recent public formal enforcement actions issued to institutions by the US federal bank regulatory agencies (Agencies) — the Board of Governors of the Federal Reserve System...more

Thomas Fox - Compliance Evangelist

The Boeing Plea Agreement-A Major Disconnect

In its proposed Plea Agreement, the Department of Justice (DOJ) lays out the abject failures of Boeing which led the DOJ to conclude the underlying Deferred Prosecution Agreement (DPA) from 2021 has been breached. The DOJ...more

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