Biden

Today we pivot back to the incoming Biden Administration and what corporate compliance officers should anticipate as we all plan budgets and priorities for 2021. We have more insight now into who might lead important regulatory agencies under President Biden, and into what policy goals or enforcement efforts a Biden Administration would be able to…

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COSO

COSO and the Society of Corporate Compliance & Ethics released guidance today about how to integrate corporate ethics and compliance concerns into a company’s larger risk management program, complete with a list of best practices for compliance programs mapped to COSO’s enterprise risk management framework. It’s a useful document for people who like to think…

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Biden

Well, thank the Lord this is ending. The Trump Administration has given the United States (and the world) four years of ignorance, incompetence, immorality, greed, divisiveness, and corruption. President Trump has been a singular menace to this country and the American experiment; and also to corporations that have struggled to navigate the cultural divisions Trump…

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compliance

We finish our examination of the Citigroup enforcement action with a look at the issue most dear to compliance officers’ hearts: compliance risk, and how Citigroup needs to improve its compliance risk management function to meet regulators’ expectations. First, the backstory. On Oct. 7 the Office of the Comptroller of the Currency levied a $400…

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JPMorgan

Well here’s something to take to the board as you’re planning the 2021 budget: the Justice Department hit JPMorgan this week with $920 million in penalties and disgorgement for commodities trading fraud — a penalty that could have been even larger but wasn’t, partly because the bank spent many millions improving its compliance program.  The…

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wells fargo

Wells Fargo filed its latest quarterly report on Tuesday, and you may have seen news that new CEO Charlie Scharf wants to cut back spending on outside compliance consulting dramatically — spending that he described as “beyond anything I’ve ever seen.”  That spending, of course, stems from the seemingly endless number of compliance failures Wells…

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covid

A survey of more than 300 compliance officers finds that roughly half of you have been exclusively working from home since the Covid-19 crisis started four months ago — and while that transition hasn’t been as bad as you’d feared, concerns about compliance failures and budget cuts are rising swiftly. So says a report from…

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compliance

The Justice Department updated its guidance for evaluating effective compliance programs on Monday, adding new material about how often a company reviews the structure of its program, a compliance officer’s access to data, and how companies integrate acquisitions into their existing programs.  The department posted the update without fanfare on Monday afternoon, and had made…

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cftc

The Commodity Futures Trading Commission updated its enforcement manual last week for the first time in 26 years, with a heap of attention paid to the importance of corporate compliance programs when firms are looking to reduce potential monetary penalties.  The update, published as a four-page memo from the CFTC Enforcement Division on May 20,…

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budget

The law firm Hogan Lovells just published a report on compliance department budgets and staffing that paints a troubling picture on both fronts. Since budgets and manpower are crucial to any compliance officer’s success on the job, let’s take a look at the details. The broad message is simple. Businesses in North America and Europe…

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