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SEC Enforcement and Compliance Priorities: A Renewed Focus on Enforcement and Accountability

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. Read More


More Than Due Diligence: Never-Ending Due Diligence

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 ... Read More

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OFAC: Best Practices for P&C Insurers

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. Read More


Corporate Wrongdoing and Deterrence

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. Read More

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Hot Buttons in Executive Compensation

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... Read More


Managing Corruption Risk

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 ... Read More


Fraud and Bribery – They Go Hand in Hand

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, ... Read More

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Conflict Minerals: Compliance Considerations and Takeaways

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 ... Read More

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The 3 Dimensions of Risk

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 ... Read More

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