News & Analysis as of

Risk Management Cooperative Compliance Regime

J.S. Held

INDEPTH FEATURE: Corporate Fraud & Corruption 2024

J.S. Held on

To what extent are boards and senior executives in your country of focus taking proactive steps to reduce incidences of fraud and corruption from surfacing within their company? Over the past several years, there has been...more

Ballard Spahr LLP

DOJ Launches Whistleblower Pilot Program and Cracks Down on AI Misuse

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The Department of Justice (DOJ) has unveiled a new whistleblower policy designed to incentivize individuals to disclose corporate misconduct through financial rewards from any resulting forfeiture of criminal proceeds. The...more

Robinson+Cole Environmental Law +

EPA Audit Policy Update – Scrutiny of Voluntary Self-Disclosures Set to Increase

The EPA intends to increase its review of voluntary self-disclosures of violations submitted electronically under EPA’s Audit Policy. The EPA Office of Inspector General (OIG) recently issued a report detailing the results of...more

Dechert LLP

Measure Twice, Cut Once: New DOJ Compliance Certifications Put CEOs and CCOs at Risk of Individual Criminal Liability

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Key Takeaways - As DOJ senior leadership signaled it would do since March, DOJ has now officially required as part of resolving a corporate enforcement action, that a Chief Compliance Officer (CCO) and Chief Executive...more

Foodman CPAs & Advisors

Agencies Request Information To Assist With BSA Laws And Regulations Compliance

On April 9, 2021, the federal banking regulatory agencies (the Federal Reserve, FDIC and OCC) together with FinCEN and the National Credit Union Administration issued a joint statement addressing how risk management...more

Mitratech Holdings, Inc

Operationalizing GRC in Context of Legal & Privacy: Going the Last Mile

Mitratech Holdings, Inc on

However, too often the focus on GRC technology is limited to the process management of forms, workflow, tasks, and reporting. These are critical and important elements, but the role of technology for GRC is so much broader to...more

Mitratech Holdings, Inc

Aligning Vendor Risk Management to US Department of Justice Expectations

In June 2020, the US Department of Justice Criminal Division (DOJ) released an updated “Evaluation of Corporate Compliance Programs” notification. Our (and maybe your) first reaction upon hearing of this doctrine was likely,...more

Mitratech Holdings, Inc

COVID Risk Events and DOJ Compliance Expectations

To say it’s a challenge might be an understatement: Many managers are wondering to what extent their regulators will allow them to modify compliance standards during COVID-19....more

Mitratech Holdings, Inc

On Coronavirus and ‘Business As Usual’ in Unusual Times

There may never have been a situation quite like the one businesses find themselves in right now, as the COVID-19 pandemic creates an unprecedented range of challenges. Those will demand unprecedented and proactive solutions...more

Morgan Lewis - Health Law Scan

Mere Differences of Judicial Opinion Emerge to Muddle Healthcare Providers False Claims Act Exposure for Mere Differences of...

In the Care Alternatives False Claims Act (FCA) appeal, a panel of the US Court of Appeals for the Third Circuit on March 4 reversed the summary judgment granted to hospice provider Care Alternatives at the district court,...more

Carlton Fields

Construction Contractors Take Note: OFCCP’s Industry-Focused Technical Assistance Guide (TAG) May Prove Helpful in Preparing for...

Carlton Fields on

Federal construction contractors are barred from discriminating in employment on the basis of race, color, religion, sex, sexual orientation, gender identity, national origin, disability, or covered veteran status, and many...more

The Volkov Law Group

Keeping Your Eye on the Risk Ball

The Volkov Law Group on

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

The Volkov Law Group

OFAC Sanctions Compliance: 2019 a Game-Changing Year (Part II of II)

The Volkov Law Group on

Moving on, 2019 was a big year in OFAC compliance. The Sanctions Compliance Guidance was a major change in sanctions compliance. OFAC has set high expectations for compliance. Whether companies have received and responded to...more

Mitratech Holdings, Inc

Holiday Obligations and Compliance Management

The parallels with compliance management - Think about it: The challenges you face in managing your compliance obligations aren’t unlike bringing the family together for the holiday meal…you have to round everybody up,...more

Orrick, Herrington & Sutcliffe LLP

Russia Significantly Increases Fines for Violations of Data Localization Requirement

Under Russian Data Protection Law, when collecting personal data, data operators (controllers) must ensure that recording, systematization, accumulation, storage, updating and extraction of personal data relating to Russian...more

Franczek P.C.

Update on ISBE’s Emergency Rules for the Use of Seclusion and Restraint

Franczek P.C. on

As we previously reported, effective immediately, school districts must comply with ISBE emergency rules for the use of seclusion and restraint....more

Ballard Spahr LLP

FinCEN Issues Advisory on Foreign Jurisdictions with AML Deficiencies

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On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more

Thomas Fox - Compliance Evangelist

Films of Val Lewton: Part 3 – I Walked with a Zombie and 20 Questions for the Board

Let’s consider a list of 20 questions to reflect the oversight role of directors. These are questions the Board should ask of both senior management and the Board itself. The questions are not intended to be an exact...more

Ballard Spahr LLP

As California Consumer Privacy Act Effective Date Looms, Companies Should Assess Need to Comply

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The California Consumer Privacy Act (CCPA) imposes a broad array of new legal obligations on businesses to inform consumers about the categories of personal information being collected online and how it will be used....more

K2 Integrity

Art and AML: Regulators Taking a Broad Brush Approach Using Financial Entity Regulatory Compliance as the Model for the Art World

K2 Integrity on

What do people see when they look at a piece of fine art—such as a painting by Cezanne, a sculpture by Giacometti, or a three-dimensional combine by Rauschenberg? To a great extent, it depends on who’s doing the looking. An...more

Littler

12 Months Since GDPR - What Do Employers Really Need to Know?

Littler on

As we sip champagne reflecting on the first anniversary of the effective date of the European General Data Protection Regulation (GDPR), we consider the obligations that employers should bear in mind....more

Bricker Graydon LLP

U.S. hospitals will continue to grapple with GDPR compliance in 2019

Bricker Graydon LLP on

When the European Union’s General Data Protection Regulation (GDPR) became effective on May 25, 2018, many US-based hospitals struggled to determine whether they were subject to the GDPR and, if so, what they must do to...more

Mitratech Holdings, Inc

The Google Walkouts – The Next Stage for #MeToo and GRC

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How is the #MeToo movement driving demand for greater personal accountability from both workers and management?...more

Akerman LLP - HR Defense

Employing Anyone in New York? New Anti-Harassment Laws Taking Effect

All employers with even a single employee working in New York City or New York State will be required to meet requirements designed to address sexual harassment under new city and state laws....more

Littler

OFCCP Focused Reviews Coming in FY 2019

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On August 10, 2018, the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) issued a new directive, 2018-04, announcing a plan to implement focused reviews of contractors’ compliance with Executive...more

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