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Employee Training Internal Controls Compliance

NAVEX

The Value of a Platform Approach to Compliance

NAVEX on

Think of it as the compliance version of The Butterfly Effect – a small, unnoticed, action, or failure to act, somewhere in the organization that balloons over time into a much larger, material issue. Maybe an employee is...more

Seward & Kissel LLP

FinCEN Proposes AML Requirements for Certain Investment Advisers

Seward & Kissel LLP on

On February 13, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (the “Proposed Rule”) that would subject registered investment advisers (“RIAs”) and...more

Thomas Fox - Compliance Evangelist

A Shifting Mindset Towards Prevention

I do not think it would be too controversial to say that compliance programs play a crucial role in ensuring that organizations adhere to legal and ethical standards. That is basically what we are all striving to do. However,...more

StoneTurn

Trust and National Security: Lessons for Business Insider Threat Programs

StoneTurn on

The recent arrest and criminal charges against Airman First Class Jack Teixeira for the alleged posting of classified and sensitive information on social media is yet another example of the significant risk that trusted...more

Hogan Lovells

[Webinar] Controlling your risk and regulatory obligations with a hybrid workforce – is that even possible? - May 12th, 11:00 am -...

Hogan Lovells on

Hybrid working maybe the new norm in 2022 but the FCA is keeping a watchful eye on how firms continue to meet their regulatory responsibilities and effectively control the risks. With the regulator reviewing a firm's remote...more

NAVEX

IT and Corporate Compliance: Bridging the Gap in the Era of Remote and Hybrid Work

NAVEX on

In many ways, the COVID-19 pandemic has served as a prime example of punctuated equilibrium. Shifts that have been slowly building for decades seemingly occurred overnight, giving us the contradictory sense that these changes...more

NAVEX

4 Ways to Protect ePHI Beyond HIPAA Compliance

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Given the choice between credit card data and digital health records, cybercriminals prefer the latter. A stolen credit card can be canceled. Electronic protected health information (ePHI) with its treasure-trove of...more

Thomas Fox - Compliance Evangelist

Ongoing Training and Communications in Compliance

This week on Innovation in Compliance, in a five-part podcast series, sponsored by K2 Intelligence FIN, we consider defining and building effective compliance programs. ...more

Thomas Fox - Compliance Evangelist

The OFAC Compliance Framework: Element 4 & 5 – Testing and Auditing & Training

After a short visit to Val Lewton’s Cat People, I return to conclude this multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand...more

The Volkov Law Group

Five Important Mandates from OFAC Compliance Framework

The Volkov Law Group on

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

Dechert LLP

Revised DOJ Policy on Antitrust Compliance Offers New Opportunities for In-House Counsel to Protect Their Companies

Dechert LLP on

Question: Can a company have both an effective antitrust compliance program and an antitrust violation? DOJ before June 11, 2019: Nope. DOJ today: Yes, and your company may even get a deferred prosecution agreement if...more

King & Spalding

Corporate Compliance Programs: DOJ Issues Updated Guidance: Ten Takeaways for In-House Legal and Compliance Leaders

King & Spalding on

On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas. In issuing the new document (the...more

Pillsbury Winthrop Shaw Pittman LLP

Time to Update Corporate Compliance Programs Following DOJ Guidance

Companies must now address three questions proactively. On April 30, 2019, the DOJ’s Criminal Division issued updated guidance on how it will evaluate corporate compliance programs in its charging decisions going forward....more

Cozen O'Connor

OFAC Issues Compliance Guidance to Companies

Cozen O'Connor on

On May 2, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance Commitments. In this document, OFAC outlines its expectations for effective sanctions...more

King & Spalding

OFAC Publishes “A Framework for Compliance Commitments”

King & Spalding on

OFAC Provides Guidance on the Essential Components of a Risk-Based Sanctions Compliance Program - On May 2, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury issued guidelines...more

The Volkov Law Group

DOJ’s New Corporate Compliance Guidance: Training and Communications, Reporting and Investigations, Third-Party Management and...

The Volkov Law Group on

The Justice Department’s new Corporate Compliance Guidance is keyed to the concept of a “well-designed compliance program.” Under this concept, we first examined risk assessments and policies and procedures. ...more

The Volkov Law Group

The Important Link Between Anti-Corruption Compliance and Effective Training Programs

The Volkov Law Group on

Global anti-corruption risks are increasing at the same time that global cooperation among prosecutors and law enforcement agencies are facilitating the detection and penalization of companies and individual bad actors that...more

The Volkov Law Group

Fraud Detection: New Technologies and Analytics (Part II of III)

The Volkov Law Group on

The battle against fraud is evolving and technology is providing new and important tools to detect and prevent fraud. Companies are using a variety of techniques and include: continuous monitoring; email monitoring; anomaly...more

Thomas Fox - Compliance Evangelist

What is the role of a CCO in strengthening the ethical culture of an organization?

Today, I want to consider what is the role of a Chief Compliance Officer (CCO) in strengthening the ethical culture of an organization.  This blog post is based on, in part in an interview I did with Eric Feldman from...more

Thomas Fox - Compliance Evangelist

Operationalizing compliance through tailored compliance training

I have considered this in the context of third-parties, forecasting and the risk management process and through the use of a root cause analysis. Today, I want to conclude this week’s blog posts with a post on...more

The Volkov Law Group

In Defense of Compliance Checklists

The Volkov Law Group on

Compliance officers have to avoid complicating a compliance program. As in many areas in life, there is a value in simplicity. Take for example a compliance training presentation. If a compliance officer overwhelms his/her...more

Thomas Fox - Compliance Evangelist

The Uber Board Report – Part II: Internal Controls

I continue my blog post series on the Holder Report (Report) to the Board of Directors of Uber Technology, Inc. (Uber) where the Board asked Holder’s law firm, Covington & Burling LLP (Covington), to evaluate three issues:...more

Foley & Lardner LLP

White Collar Enforcement and the New Trump Administration: Your Top Ten Questions Answered

Foley & Lardner LLP on

Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more

Thomas Fox - Compliance Evangelist

The Unsinkable Molly Brown – Compliance, Stakeholder Engagement and CSR

Tammy Grimes died earlier this week. For those of you not familiar with that name, you may well know the name of the Broadway musical which catapulted her to fame, The Unsinkable Molly Brown. Grimes garnered a Toni in 1960...more

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