News & Analysis as of

Securities and Exchange Commission (SEC) Risk Management Third-Party

NAVEX

What a New SEC Enforcement Sweep Is Really Telling Us

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Attention all compliance officers at large technology companies – have you checked your mail lately? Because you might find a letter from the Securities and Exchange Commission with FCPA risk written all over it....more

NAVEX

SEC Rule or Not, Keep Your Eye on the Climate Change Ball

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The U.S. Securities and Exchange Commission recently announced that its long-awaited greenhouse gas disclosure rule will be delayed yet again, most likely until April 2024. This raises an important question for compliance and...more

Perkins Coie

DOJ Issues New Guidance on Use of Personal Devices and Third-Party Messaging Applications

Perkins Coie on

The U.S. Department of Justice (DOJ) announced significant new guidance on March 3, 2023, regarding the use of personal devices and the retention of corporate communications. The DOJ’s concern regarding the use of personal...more

Perkins Coie

New DOJ Guidance on Personal Devices and Third-Party Messaging Applications Applies to Any Company DOJ May Scrutinize

Perkins Coie on

The U.S. Department of Justice (DOJ) recently released new guidance announcing several policy changes to further strengthen and clarify its approach to prosecuting corporate crime. The guidance, released through a memorandum...more

Dechert LLP

SEC Adopts Amendments to Rule 17a-4 Electronic Recordkeeping Requirement

Dechert LLP on

The Securities and Exchange Commission on October 12, 2022, adopted amendments to the electronic recordkeeping requirements for broker-dealers, security-based swap dealers (SBSDs), and major security-based swap participants...more

The Volkov Law Group

DOJ and SEC Raising the Stakes on Third Party Risk Management

The Volkov Law Group on

If you review the last ten years of FCPA enforcement, the unmistakable pattern is rising expectations with regard to corporate compliance programs, particularly with regard to third party due diligence and risk management....more

Hinshaw & Culbertson LLP

The Lawyers' Lawyer Newsletter - Recent Developments in Risk Management - August 2016

Joint Clients — Confidentiality — Right to See Clients' File - New York State Bar Association Committee on Professional Ethics Opinion 1070 (10/9/15) - Risk Management Issue: In a joint client representation, if one...more

Broker-Dealer Compliance + Regulation

Cybersecurity, Round 2: OCIE Announces Areas of Focus for Cybersecurity Examinations

On September 15, 2015, OCIE issued a risk alert relating to its new cybersecurity examination initiative. This is the second round of these examinations, and the alert provides a detailed look at OCIE’s current areas of...more

Morgan Lewis

SEC and DOJ Hacking Prosecutions Highlight SEC’s Increased Interest in Cybersecurity Risks

Morgan Lewis on

Companies are reminded of the need for strong internal controls. The US Securities and Exchange Commission (SEC) and the Department of Justice (DOJ) recently filed civil and criminal actions in the largest hacking and...more

NAVEX

Implementing an Effective Third Party “Audit” Program

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Explore new approaches to third party audits for a more effective, risk-aligned third party risk management program.    Compliance officers have been insisting on (and should continue to insist on) including third party...more

NAVEX

Third Party Risk in a Global Environment

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Most organizations engage with hundreds, if not often thousands, of third party vendors, suppliers, agents and business partners, creating a daunting and ever-expanding scope of risk. This risk arises from: 1....more

NAVEX

A Prescriptive Guide To Third Party Risk Management

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The recent examples of compliance program credits for Morgan Stanley and Ralph Lauren have demonstrated that, more than ever, an effective compliance program can protect a company from criminal indictment and generate bottom...more

The Volkov Law Group

Anti-Corruption High-Risk Audits

The Volkov Law Group on

The Justice Department and the SEC should be credited with promoting new compliance strategies and best practices. Whatever you may think about the DOJ/SEC FCPA enforcement program, they have pushed businesses to enhance...more

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