September 29, 2014
Russian Roulette with Security Breaches

  • Jason Hart

  • Many organizations aren't taking data security seriously, despite the fact that hackers continue to breach relatively secure systems at large corporations, subjecting those companies to reputational harm and loss of consumer trust. Some have recovered just fine, but smaller businesses don't bounce back as quickly. The fact is, a breach will happen to your company, too, sooner or later....

    football 2
    September 26, 2014

  • Thomas Fox

  • The NFL has been all over the news lately, and it's not for any of its teams' upsets or losses. Not on the field, anyway. Two scandals invol...

    September 24, 2014
    Burn After Reading? A Better Approach to Securing Shared Information

  • Derek Gascon

  • A burn-after-reading approach to handling data security might be sexy, but it's not terribly practical. And except in very extreme circumstances - say, if you're dealing with international spies - it's altogether unnecessary. There are far more sensible solutions on the market already, and encrypting data, rather than attempting to restrict access to its location, is the key....

    September 26, 2014
    Preparing Effective SARs: New SAR Form, One Year Later

  • Walid Raad

  • Last year, the Financial Crimes Enforcement Network (FinCEN) updated their Suspicious Activity Report (SAR) form to allow for far more detail to be provided. The SAR is an integral part of an investigation of alleged financial crimes, and with the expanded form, law enforcement is able to get a clearer picture of the incident or incidents in question. ...

    September 25, 2014
    And the Surveys Go On

  • Linda Henman

  • We're inundated with survey requests, and they seem to come from all directions - pop-ups on websites, grocery store receipts, in the wrap-up lingo at the end of a customer service phone call... But is this really the best way for companies to be gathering information on their customer experiences? Linda Henman suggests not. Sometimes the more conventional approach is better....

    September 23, 2014
    No Fear: How Businesses Can Master Content Development on Social Media

  • Joanna Belbey

  • Sharing content on social media requires a bit of strategy in order to be most effective. To really engage the audience, your firm should create "snackable" versions of its material, avoid pitching or selling and put a good deal of thought into how information is shared, where it's posted, and when it's pushed out. Joanna Belbey offers excellent guidance on social media use....

    wall street
    September 22, 2014
    SEC Enforcement and Compliance Priorities: A Renewed Focus on Enforcement and Accountability

  • Bradley Bondi

  • The swearing in of Mary Jo White as the new Chair of the SEC ushered in a period of increased vigor in enforcement, along with tougher prosecutorial tactics. And the SEC has already delivered. To spare their organizations from these hard-nosed enforcement actions, it's incumbent upon compliance practitioners to establish and maintain strong controls, policies and programs....

    iran flag
    September 19, 2014
    OFAC: Best Practices for P&C Insurers

  • Matthew Vuolo

  • Commerce is forever becoming more global in nature, and as a result, maintaining compliance with the federal government's regulations is becoming increasingly challenging. For insurers, the issue is especially complex, as they've got to ensure that not only policyholders, but also potential recipients and third-party claimants aren't barred by the OFAC or residing on its SDN list....

    September 17, 2014
    Is Social Media/Internet Advertising the Next Monitoring Emphasis for the OIG? Part 2

  • Brian A. Dahl

  • Companies in the life sciences must actively monitor their promotional and even non-promotional activities to ensure continual compliance with FDA requirements. According to recent OIG enforcement actions, this has come to include all manner of social media activity, from "likes" on Facebook to health claims made online. Are your social media policies clear enough?...

    coin stacks
    September 16, 2014
    Hot Buttons in Executive Compensation

  • John Siemann

  • Executive compensation has been a mainstay in the news in the past few years. Concern about growing income inequality birthed the Occupy Wall Street movement in 2011 and the issue has remained on people's minds, with many incensed about the immense gap between the "1 percent" and everyone else. Here, we explore the actions companies are taking......

    September 15, 2014
    Managing Corruption Risk

  • Jim DeLoach

  • It's been made clear that violations of the FCPA can do an organization significant reputational harm and result in some very steep fines. To minimize the damage an employee or agent does to your company when engaging in corrupt behavior, you must have excellent controls in place. Even if the infraction is egregious, the fallout can be minimal....


    September 22, 2014
    More Than Due Diligence: Never-Ending Due Diligence

  • Michael Volkov

  • Conducting due diligence on third parties isn't about diving deep into every possible avenue for wrongdoing. You'd never reach the end, and it is impossible to foretell which agents will engage in corruption. Trying to pinpoint possible red flags must be guided by reasonable inquiries tied to risks. Cover your bases and you'll have covered your bottom as well....

    September 18, 2014

  • James A. Kosch

  • A select few states are leading the way in pushing manufacturers to disclose their use of toxic chemicals in con...

    September 17, 2014
    Corporate Wrongdoing and Deterrence

  • Michael Volkov

  • How effective is corporate punishment when it comes to deterring illegal behavior? That's the question. The U.S. Sentencing Commission may soon be taking a harder line against corporations involved in cartel activity, though some experts question whether individual punishments would be better deterrents. 108 months of jail time could really drive home the message....




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    September 15, 2014
    Pro Football and the FCPA Professor

  • Thomas Fox

  • Ah, September: bringer of fall, sweater weather, and football. Compliance practitioners and lovers of football alike can appreciate the parallels between the sport and the nuts and bolts of FCPA compliance. The success of both teams relies heavily, for instance, on a strong understanding of the game plan. Tom Fox outlines a few other shared characteristics... ...

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    Preventing Employees from Hoarding Documents



    Fundamentals of Project Management (12 PDUs)



    1099 and W-9 Update - Complying with IRS Information Reporting

    September 12, 2014

  • Michael Volkov

  • Bribery doesn't exist in a vacuum. In order for funds to change hands improperly, the bribing party needs access to those funds and a way to disguise how they're truly being used. Meaning: if there's fraud going on in your organization, internal controls are quite possibly lacking and your internal auditing system leaves something to be desired, as well....

    September 11, 2014

  • Richard Bistrong

  • For some professionals engaged in corrupt behavior, often the rationale behind their impropriety is that no one is being hurt. Richard Bistrong argues that bribery is not a victimless crime. The damage done just might not be as obvious. And beware the seeming "win-win" scenarios when corruption risk is high; corruption is not in the company's best interests....

    tv shopping
    September 10, 2014

  • James Ervin

  • Remaining in compliance with the SEC's requirements to disclose use of conflict minerals is an even trickier proposition than it seems. Organizations are liable to be on the receiving end of enforcement actions if any party across their supply chain is in violation of the Conflict Minerals Rules. It's in a company's best interest to step up their auditing and due diligence efforts!...

    3D glasses
    September 9, 2014
    The 3 Dimensions of Risk

  • James Bone

  • Organizations that have a fairly firm grasp of risk management tend to do fairly well in what James Bone calls the first and second dimensions of risk. It's common, however, for firms to fall short in the third dimension. So what is this third dimension of risk, and how can risk professionals guide their firms into more robust risk management practices?...

    September 8, 2014
    Dealing with “Big Data”

  • Michael Salvarezza

  • With the constant forward march of technology and the ever-increasing popularity of BYOD programs, records and information management gets more complicated every day. Businesses must, of course, ensure they're remaining compliant with applicable regulations, but one aspect of risk management in this department may mean challenging those requirements....

    September 5, 2014
    Medicare: The Gift That Keeps On Giving

  • Craig Garner

  • Each Fall, the Centers for Medicare and Medicaid Services releases updates to regulations associated with its Hospital Inpatient Prospective Payment Systems. This year's changes span nearly 600 pages, though many updates pertain to two key topics: reducing hospital readmissions and minimizing hospital reimbursements. Here's what you most need to know....

    tech concept
    September 4, 2014
    What’s Holding Back the Internal Audit Transformation? Internal Audit’s Technology Performance Gap

  • John Verver

  • Internal audit departments have undergone significant change in recent years, a trend that's likely to continue for some time to come. In fact, IA ought to be embracing new technologies, as other departments have, to achieve greater efficiency and effectiveness. IA's failure to properly leverage technology only stunts its growth. ...