Posts Tagged ‘due diligence’
The Joys of Pre-Acquisition Due Diligence
Few issues can exasperate a compliance officer as much as pre-acquisition due diligence for a business your company wants to acquire. So when I was moderating a webinar last week on compliance issues and conversation turned to that very subject, I took notes. What if, fellow compliance enthusiasts, there’s a better way to look at…
Read MoreCity National, Part II: Customer Due Diligence
Today let’s return to that enforcement action against City National Bank, issued by federal banking regulators last week for City National’s systemic risk management shortcomings. We originally looked at the settlement order’s advice on risk assessments; next up is another common compliance challenge: customer due diligence. The recap here is that the Office of the…
Read MoreMore Help on Third-Party Risk
Banks have fresh guidance this week on how to tackle third-party risk management, and the material offers plenty of good advice on the subject for businesses in any sector. The guidance comes from the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corp., and the Federal Reserve, which have been working for…
Read MoreRobinhood, Part II: Due Diligence Fails
Today I want to return to FINRA’s enforcement action against Robinhood, that online stock trading app with the terrible track record at customer due diligence and risk profiling. Even though the case involves the somewhat rarified compliance rules for broker-dealer firms, there’s a lot here that speaks to technology and due diligence challenges overall. Robinhood,…
Read MoreDeutsche Bank Dinged on Two Sanctions Cases
Some red meat for all you sanctions compliance nerds: a Deutsche Bank subsidiary has agreed to pay $583,000 for two separate sanctions violations. One involved compliance employees improperly configuring a sanctions screening tool; the other, senior business and compliance managers rushing a transaction without appropriate due diligence. The Office of Foreign Assets Control announced the…
Read MoreRegulators Talk PEPs, Due Diligence
Banking regulators have published fresh guidance about how financial firms should perform due diligence on “politically exposed persons” — stressing that you don’t need to take extra steps simply because a customer is a PEP, although banks do need to understand the higher corruption risks PEPs can pose. The guidance is a joint statement from…
Read MoreFinCEN Gives Guidance, Says Little
Anti-money laundering regulators gave fresh guidance Monday about what financial firms should do for adequate customer due diligence — guidance that was, alas, light on specific steps to take. Instead, compliance officers have a three-page document best described as “Do what you think is best, based upon risk.” The guidance comes from FinCEN, the Financial…
Read MoreDeutsche Bank’s Misconduct: Naming Names
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…
Read MoreDeutsche Bank’s Many Epstein Failures
New York banking regulators hit Deutsche Bank with a $150 million penalty Tuesday for its business dealings with notorious sex trafficker Jeffrey Epstein, and painted a damning picture of compliance failures that went on for years at the bank while it reaped millions from such a lucrative customer. The New York Department of Financial Services…
Read MoreGoldman Sach’s Good FCPA Outcome
Chalk up another victory for effective compliance programs: Goldman Sachs just avoided FCPA charges from the Securities and Exchange Commission because its compliance team uncovered a sketchy deal one of its bankers cooked up in Ghana — while the banker himself is now facing charges from the SEC. The defendant in question is Asante Berko,…
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