Episode 343 -- TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations
Leadership Lessons From The West Wing — Hiring to Firing Podcast
Episode 342 -- How to Conduct an Internal Compliance Site Visit and Review
Wicked Coin: FIFA: Soccer, Scandal, and Sportswashing
The Presumption of Innocence Podcast: Episode 47 - Fireside Chat With Bill Baroni and Jesse Eisinger
Public-Private Partnerships to Stem Corruption
Why Privacy is Your Secret Weapon Against Third-Party Risk
Due Diligence in AI: 3 things you need to survive AI scrutiny
Episode 337 -- Nicolas Garcia, GC at Orica, on Compliance Trends and Challenges in Latin America
Navigating Government Contracts: Diana Shaw on Oversight and Whistleblower Protections
A Third Party's Perspective on Third Party Risk
Cannabis Law Now Podcast: Cannabis Companies and the Corporate Transparency Act
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
Episode 329 -- Bryn Sedlacek from Aravo on TPRM Holistic Risks and Unified Visibility
Episode 328 -- Sanctions Enforcement Risks and Redlines
Managing Corruption Risk in Latin America
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Examining FinCEN FAQs, Proposed Legislation and Other CTA Developments
Episode 320 -- NAVEX Hotline Report -- More Reports and Higher Substantiation
The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the Justice Department Fails to Prosecute Executives'
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
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
One cannot really say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program should be based on a risk assessment, on an understanding of your...more
Call me a skeptic. Call me cynical. I understand that the International Organization for Standardization (ISO) provides valuable standardization services and guidance. The ISO is comprised of 169 member countries....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
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
When the tide goes out, as it appears to be doing now with the market down 20% percent from its highs in January, bad actors will be left exposed for everyone to see. Simply put, as the market drops those companies hiding...more
Anti-money laundering authorities are proposing a significant revision to the federal AML regulatory scheme with the aim of making it more effective while providing greater clarity to covered institutions. ...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
On June 1, 2020, the Criminal Division of the US Department of Justice (“DOJ”) released an updated guidance document for white-collar prosecutors on the evaluation of corporate compliance programs....more
On June 1, 2020, the Department of Justice Criminal Division published updated guidance on an important piece of DOJ literature, the “Evaluation of Corporate Compliance Programs” (“Guidance”), which for many 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
Most experts agree that whichever regulatory jurisdiction an organisation is subject to, there are five common fundamentals involved in providing effective corporate compliance....more
In a recent update to its internal guidance, the UK Serious Fraud Office provides insight into the general approach its investigators may take for evaluating organizations’ compliance programs—an approach similar to that 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
I am in a multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand and implement some of the key concepts of the Framework into your...more
The Enforcement Committee of the French Anticorruption Agency ("FAA") handed down its first decision on July 4, 2019. The decision follows the Agency's three-month audit (October to December 2017) of the involved company's...more
As companies elevate their “game” in sanctions compliance, it is important that compliance officers critically examine the strengths and weaknesses of their compliance programs. Many companies already have a screening...more
Based on its aggressive enforcement program and its recently issued Framework for Sanctions Compliance Programs, OFAC has established a new era in sanctions compliance. Trade compliance is often siloed into its own...more