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Corporate Governance Internal Controls Risk Assessment

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

Society of Corporate Compliance and Ethics...

The value of the close call

Much has been written about the importance of identifying lessons learned and taking remedial action in the aftermath of an investigation into compliance failures. But an equally valuable exercise can result from exploring...more

Goodwin

The Coming Storm: Preparing for The SEC's Final Climate-Related Disclosure Rules

Goodwin on

On March 6, 2024, the U.S. Securities and Exchange Commission (SEC) adopted final rules that will require expansive new climate-related disclosures in Form 10-K and Form 20-F annual reports and most registration statements....more

Thomas Fox - Compliance Evangelist

Monitoring and Improvement of Internal Controls

What happens when controls are continually overridden? Does that necessarily mean that companies are engaging in activities that violate the FCPA or some other law such as Sarbanes-Oxley (SOX). Cristina Revelo said she would...more

Thomas Fox - Compliance Evangelist

Internal Controls

What are internal controls? The best definition I have come across is from Jonathan Marks, partner at BDO, who defined internal controls as: An internal control is an action or process of interlocking activities designed to...more

Thomas Fox - Compliance Evangelist

Nicholas Latham on Implementing Frameworks for Effective Risk Management in Organizations

I recently had the opportunity to visit with folks from Diligent. We look down the road at key issues in 2024 in a podcast series sponsored by Diligent entitled Compliance Professionals Adapting to Change: Industries,...more

Ankura

Economic Crime and Corporate Transparency Act 2023: Key Considerations for Addressing Failure to Prevent Fraud

Ankura on

The Economic Crime Bill received Royal Assent on 26 October 2023. Included in the Act is the failure to prevent fraud offence, under which large companies will be liable when a specified fraud offence is committed by an...more

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more

Conyers

Cayman Islands’ Corporate Governance Rule and Internal Controls Guidance and Rule

Conyers on

A reminder that the Cayman Islands Monetary Authority’s (CIMA) new Rule on Corporate Governance for Regulated Entities (Corporate Governance Rule) and Rule and Statement of Guidance on Internal Controls for Regulated Entities...more

Society of Corporate Compliance and Ethics...

Don't be alarmed

Two stories in the news recently caught my eye. In the first, a janitor allegedly shut off the power to a freezer after hearing “annoying alarms.” He ended up ruining decades of research. In the other story, an American...more

BakerHostetler

SEC Chief Accountant Warns About Need for Comprehensive Risk Assessments

BakerHostetler on

For years, regulators have emphasized that the starting point for maintaining an effective compliance program is understanding the particular risks the company faces. According to Munter, this same concept applies to...more

Health Care Compliance Association (HCCA)

Compliance in someone else’s shoes

The Wall Street Journal recently reported that the CEO of Uber spent time driving for the company under an assumed name. He filled out the forms like any prospective driver and drove around customers....more

NAVEX

Your Questions, Answered – Risk and Process Management Framework: Lessons Learned in Getting Started, Featuring Forrester

NAVEX on

Recently, NAVEX hosted the webinar, “Risk and Process Management Framework: Lessons Learned in Getting Started,” featuring Cody Scott from Forrester. This session delved into how to break down silos between the cybersecurity...more

NAVEX

Risk and Process Management Framework: Lessons Learned in Getting Started

NAVEX on

Risk – it’s most detrimental when you don’t see it coming. Running any size business means anticipating and accepting some risks and establishing controls to mitigate others. Risk often originates from inside the business...more

The Volkov Law Group

Refreshing and Elevating Your Sanctions Compliance Program (Part II of III)

The Volkov Law Group on

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

Cooley LLP

COSO introduces ”internal control over sustainability reporting”

Cooley LLP on

Under the pressure of institutional investors, environmental groups, employees, consumers and other stakeholders, many companies have sought to demonstrate their bona fides when it comes to ESG through disclosure about their...more

NAVEX

New Expectations of Executive Leadership – How Will You Prove and Certify Your Program Works?

NAVEX on

As compliance officers enter 2023, they need to learn how to handle a double-edged sword: the Justice Department’s new requirement that as part of corporate misconduct resolutions, CCOs must certify the effectiveness of their...more

Holland & Knight LLP

Risky Business: SEC Expands DCP Enforcement Using Company Risk Factors

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Outside of the small circle of federal securities law nerds (we proudly proclaim our membership), the phrase "disclosure controls and procedures" (DCP) rarely garners much attention. However, a recent settled order issued by...more

BCLP

SEC penalizes company with good disclosures for insufficient controls

BCLP on

What happened? In a recent settlement order, the SEC charged Activision Blizzard with failing to maintain adequate disclosure controls and procedures. Notably, the SEC did not claim that the company’s SEC filings were...more

Orrick, Herrington & Sutcliffe LLP

Assessing Risk to Bolster Compliance: Key Questions to Ask

An effective compliance program evolves with risk, and changes in the market are an important part of assessing risk. Given the unprecedented, rapid changes in the business landscape – internal and external – companies should...more

Holland & Knight LLP

NYDFS Proposes Amendments to Cybersecurity Regulation

Holland & Knight LLP on

The New York Department of Financial Services (NYDFS) on Nov. 9, 2022, released Proposed Amendments to its Cybersecurity Regulation. The NYDFS Cybersecurity Regulation was one of the first laws requiring companies to comply...more

The Volkov Law Group

Tracking Ethics and Compliance Program Performance (Part II of II)

The Volkov Law Group on

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

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - July 11th - 14th, Singapore, Singapore

Are you looking to better… - Support, enhance, and manage a compliance and ethics program? - Mitigate risk within your organization? - Understand the components of effective program infrastructure? SCCE’s Basic...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - June 20th - 23rd, Amsterdam, Netherlands

Are you looking to better… - Support, enhance, and manage a compliance and ethics program? - Mitigate risk within your organization? - Understand the components of effective program infrastructure? SCCE’s Basic...more

Society of Corporate Compliance and Ethics...

[Virtual Event] ESG and Compliance Conference - April 26th, 7:55 am - 3:15 pm CDT

Discover how to set and accomplish your ESG goals - Environment, Social, and Governance (ESG) is no longer an isolated function within a company, nor is it an issue only for publicly traded companies. It’s front and...more

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