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Bank Secrecy Act Compliance During the COVID-19 Crisis

The COVID-19 outbreak has affected all of us and we now face the new normal of self-quarantine and social distancing.  As Anti-Money Laundering (AML) professionals, we are still required to ensure that financial institutions...more

COVID-19: Crisis Management

Companies dedicate time and resources to enterprise risk management.  This is a much broader focus than legal and compliance risks – instead, enterprise risks identifies some of the major catastrophes  — e.g. one company had...more

Ethical Business Decisions in the COVID-19 Crisis

These are scary times.  We have not experienced such a crisis in our lifetimes.  9-11 was a traumatic event with a tragic impact on our country.  ...more

The Coronavirus Pandemic: A Call for Leadership

We need leadership from our President and our federal government.  Instead of appearing for self-congratulatory press conferences, and pushing responsibilities to state and local governments, the White House needs to direct a...more

Antitrust Compliance Programs: Training and Speak Up and Reporting Systems (Part III of III)

Many global companies are behind the eight-ball (translation, slow to implement) effective antitrust compliance programs.  A small number of companies, some of which have suffered antitrust enforcement actions or operate in...more

[Webinar] Maintaining a Reliable and Effective Internal Investigation Program - March 24th, 12:00 pm EST

A company's commitment to implementing an effective ethics and compliance program must include a reliable internal investigation program. In order to build trust and a speak up culture, an internal investigation program has...more

Antitrust Compliance Programs: Ethical Culture and Monitoring (Part II of III)

Like all compliance programs, a company lives or dies based on its ethical culture.  A company with a poor culture that operates in a concentrated competitive market has significantly higher antitrust risks than companies...more

[Webinar] How to Implement an Effective OFAC Sanctions Compliance Program - March 31st, 12:00 pm EST

In 2019, the Department of Treasury’s Office of Foreign Asset Control (OFAC) issued important guidance on sanctions compliance programs. OFAC’s guidance sets out new and prescriptive requirements for sanctions compliance...more

Five Key Elements of an Antitrust Compliance Program: Risk Assessments (Part I of III)

In July 2019, the U.S. Justice of Department’s Antitrust Division ended a long-running controversy surrounding compliance program credit by issuing its Evaluation of Corporate Compliance Programs in Criminal Antitrust...more

“Paralysis” and a Culture of Wrongdoing

We all are familiar with the “horror” stories circling numerous infamous corporate scandals – Wells Fargo, Boeing, General Motors, Airbus, Ericsson, HSBC and on and on.  When you read about each of these scandals, layer by...more

The Pandemic Crisis – A Note of Support

I have to admit that it is hard to maintain this blog under the current circumstances.  It is hard to ignore the “elephant in the room.” ...more

Addressing the Coronavirus Crisis and Corporate Response

In this global pandemic crisis, every company is being tested.  No matter how much time was put into emergency planning it is difficult to imagine that anyone could have foreseen the scope and nature of the current crisis....more

United Bank Risk Officer Agrees to $450k Penalty for AML Compliance Failures

Compliance professionals face extraordinary risks – not just for the enterprise but personal risks.  CCOs should not panic or overreact when the government brings an enforcement action against a compliance officer for a...more

The Danger of a Hyper-Focused Sales Culture

We all know that economic incentives are critical to promoting performance.  Going back to the days of Adam Smith, the U.S. economic growth is the result of a basic motivation – hard work can result in significant...more

Swiss Telecomm Company Pays $7.8 Million to Settle OFAC Sanctions Violations

OFAC continues to aggressively enforce its sanctions programs.  In its latest enforcement action, OFAC agreed with Société Internationale de Télécommunications Aéronautiques SCRL (“SITA”), a Swiss telecom company, to an...more

Admit It – Your Compliance Program is Not Really “Effective”

Chief compliance officers are heroes.  They labor every day to advance a company’s ethics and compliance program without much recognition, with few resources, and with well-known gaps in their programs....more

The Impact of a New CEO

Businesses have to evolve in order to respond to the market, consumer demands, societal pressures and stakeholder expectations.  Companies grow and pivot in two ways – organically or through acquisition or sales of parts....more

Incident Data and Intra-Company Cooperation

The Justice Department “listens and learns” from companies and compliance practitioners.  As part of every enforcement action, DOJ prosecutors review and assess compliance programs in accordance with the standards explained...more

Fourth Circuit Overturns Federal Prosecutors’ Use of Filter Team to Conduct Search of Law Firm Documents

The Fourth Circuit joined the fast-growing club of federal courts objecting to federal prosecutors and agents reliance on so-called “filter-team” procedures to review documents seized from a law firm that may contain...more

The Dangerous Mix of Incentives and “Misconduct”

We often hear about the dangerous risk to a company’s culture from rigorous sales incentive programs.  Like most issues, the answer to this issue is not cut and dried....more

Rebalancing Third-Party Risk Strategies

As companies move forward on third-party risk management programs, and as automated third-party risk solutions are being implemented, compliance professionals have to re-examine and re-balance the allocation of resources and...more

Episode 127 -- Deep Dive into the OCC Enforcement Action Against Wells Fargo CEO and Senior Executives [Audio]

In a comprehensive enforcement action, the Office of the Comptroller of Currency (OCC) announced a $17.5 million settlement with former Wells Fargo Bank CEO John Stumpf for his role in the sales practices misconduct scandal....more

2/16/2020  /  Compliance , Ethics , OCC , Popular , Wells Fargo

The “Old” Board Governance Model Needs to Change

Corporate boards are under increasing attack by investors, shareholders and the public.  In the aftermath of corporate legal train wrecks, such as the Wells Fargo, Volkswagen Emissions, General Motors, J.P. Morgan 1MDB...more

Keeping Your Eye on the Risk Ball

Compliance officers face almost an infinite number of risks – not to be trite, but CCOs can drive themselves crazy identifying every plausible legal and compliance risk a company faces.  I am exaggerating a little bit to make...more

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