collaboration

Last week I spoke on a webinar about the role that compliance officers should play in helping to guide a firm’s electronic communications. After all, coronavirus has forced tens of millions to work remotely, so the use of “collaboration tools” such as Slack, Zoom, Microsoft Teams, and similar apps is soaring.  Well, what are the…

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cybersecurity

Today we circle back to enterprise cybersecurity and its role in effective corporate compliance. Why? Because researchers recently discovered a vulnerability in SAP software that lets attackers infiltrate your IT systems to steal personal data, alter financial transactions, or otherwise cause all sorts of mischief that would saddle your business with huge compliance concerns. The…

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political

We have an interesting item from the National Labor Relations Board this week addressing a point of workplace culture that I suspect has grown quite sore for many businesses in 2020. How much discretion do you have to fire employees for their political views?  The NLRB published an advice memo on Monday about a union…

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investigation

All you criminal procedure mavens out there might be interested in a ruling from a federal district court in New Jersey this week, where two business executives facing FCPA charges were quibbling over whether the Justice Department and the SEC conducted a “joint” investigation into their alleged crimes.  Apparently that question matters because the defendants…

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cybersecurity

I missed this until now, but several weeks ago the New York Department of Financial Services filed charges for the first time under that state’s cybersecurity regulations. We have a cornucopia of lessons to consider here about risk assessment, policy management, and more.  DFS filed charges against First American Title Insurance Co., for poor management…

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domestic

Several weeks ago compliance professionals saw two enforcement actions involving energy companies implicated in bribing government officials here in the United States. They were sobering reminders that FCPA-like misconduct can happen right here at home, too.  Today I want to pick up that thread again, with a deeper look at how domestic corruption risks do…

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Chinese

Amid the many executive orders and memoranda President Trump has ballyhooed lately, let’s not forget this sneaky little number: a proposal that Chinese businesses listed on U.S. stock exchanges must submit to U.S. auditing standards.  Right now, Chinese firms don’t have to do that. Rather, they can publish financial statements audited by Chinese audit firms;…

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hotline

An interesting question cropped up this week on a corporate compliance chat board I often visit: How should a compliance officer test his or her external hotline provider?  In respect for the commenters’ privacy, I won’t identify the chat board here; suffice to say, many of you probably already know the group that operates the…

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domestic

Compliance professionals got a lucky break this week. Twice in a matter of days, we saw major scandals break involving corporate misconduct and corrupt domestic government officials here in the United States — demonstrating, yet again, that tying corporate compliance on the Foreign Corrupt Practices Act alone is tremendously short-sighted.  First we had a case…

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Deutsche Bank

We have a follow-up to last week’s news about Deutsche Bank and its many compliance failures that allowed convicted sex trafficker Jeffrey Epstein to remain a client for years: the New York Times has identified several executives, including one of the bank’s senior compliance officers, involved in those decisions. New York banking regulators hit Deutsche…

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