UBAF

We have our first enforcement action of 2021 to review: an $8.5 million fine that the Office of Foreign Assets Control slapped against a French bank for sanctions violations related to Syria, with a detailed list of compliance reforms the bank implemented to avoid harsher penalties.  OFAC announced the enforcement action on Monday against Union…

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2021

That’s it, folks: the hellish 365 days otherwise known as 2020 is now over. It was a brutal, bitter year; and the consequences of pandemic, recession, and political rancor will echo for years to come.  Those consequences, however, will start to come immediately. So before we return to the grind of emails to answer and…

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compliance jobs

Welcome to the final Compliance Jobs Report of 2020! We have new hires this week at BMW, Sobi, Zai Labs, the AICPA, and others; plus internal promotions at Timken, MUFG, the City of Chicago, and Autodesk. Job openings to note in Washington, Texas, and Georgia; and our Meme of the Week is just a happy…

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vaccine

The U.S. Treasury Department is warning financial firms to be on the lookout for frauds and cyber attacks related to covid vaccines, and asking for some tweaks to what firms include in Suspicious Activity Reports that you might file in connection with vaccine scams.  FinCEN, the enforcement wing of the Treasury Department, published the guidance…

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hotline

OK, compliance professionals — time to put on your thinking caps! One of our colleagues in the emerging markets wrote to me the other day looking for advice about who should manage a company’s internal reporting hotline. Let’s give him some help.  My friend hails from a second-tier country in the Asia-Pacific region, one moving…

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SPACs

The Securities and Exchange Commission has published fresh guidance detailing how special-purpose acquisition companies — those corporate contraptions designed to go public first and then acquire other operating businesses later — should disclose conflicts of interest, financial incentives for management, acquisition strategies, and related issues. SEC staff released the guidance on Dec. 22 as a…

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disclosure

The Extractive Payments Rule adopted by the SEC last week was notable because all five commissioners published explanatory statements along with their votes. Those statements, in turn, are notable for their dueling messages about business conduct and what counts as material information for investors under federal securities law.  Compliance officers should give this conflict some…

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algorithms

Compliance professionals searching for cutting-edge policy management mishaps, turn your gaze toward Stanford University. The mess that the medical school endured last week with its bungled distribution of covid vaccines to employees offers lessons to us all.  What happened? According to press reports and many unhappy people on Twitter, Stanford Medicine started rolling out its…

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compliance jobs

Compliance officers appointed to corporate boards — not one, but two of them, included in the Compliance Jobs Report this week! Plus news from CBRE, FINRA, and a few life sciences firms. We have job openings from Boston to Cleveland to San Francisco, and our Meme of the Week goes out to the audit team.…

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rule

The Securities and Exchange Commission has enacted a new rule for what oil & gas and mining companies must disclose to investors about payments made to foreign governments — a weaker version of a rule the SEC was forced to repeal in 2017, and which drew sharp criticism from the SEC’s lead Democratic commissioner. The…

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