Compliance

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5 Common Weaknesses in OFAC Sanctions Compliance Programs

If your business activities take place in the U.S., you need to be doing OFAC screening. Michael Volkov offers five areas most companies that most organizations fitting this description could stand to improve upon to ensure compliance. As companies elevate their “game” in sanctions compliance, it is important that compliance officers critically examine the strengths and weaknesses of their compliance...

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Remedies and Compliance in Suspension and Debarment

Jay Rosen’s miniseries on suspension and debarment concludes with this look into the remedies federal agencies seek when misconduct is identified, and where the ultimate focus will lie: compliance. The defense community largely led the process of putting together an effective ethics and compliance program. There were defense industry initiatives where the contractors got together and talked about what it...

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The Overwhelmed CCO

A CCO’s most valuable resource is time. But with high expectations and limited resources to do the job well, CCOs can quickly become overwhelmed. Michael Volkov provides a framework for dealing with some of the role’s greatest challenges. Chief compliance officers have a hard job. CCOs know that fact, and they fully embrace the challenges of their positions. At the same...

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Between Scylla and Charybdis: Chinese Banks Navigate PRC Secrecy Laws and US Subpoenas

Wendy Wysong and team discuss a recent U.S. court ruling that reinforces the well-understood rule that non-U.S. banks with branches or correspondent accounts in the U.S. must comply with U.S. government subpoenas regardless of their own country's laws. Under the USA PATRIOT Act, noncompliance risks access to the U.S. financial system. with co-authors Ali Burney and Nick Turner Background On...

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No-Fail Events to Take the Pulse of Your Compliance Program

Do you ever wish you could take a quick “pulse check” to see how your compliance education is landing – to identify subject areas that need improved awareness and know with certainty what your people really need? Fresenius’ Mary Shirley offers some fresh ideas. Risk Assessments and Culture of Integrity Surveys vs. Pulse Check I bet you already have a...

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Summer Reading List for Cyber Experts

Fact is often stranger than fiction. Cybersecurity professionals know that for sure. Abacus Group’s CTO, Paul Ponzeka recommends these books to enlighten, educate and entertain cybersecurity pros and others interested in the topic. Cyber War: The Next Threat to National Security and What to Do About It By: Richard A. Clarke and Robert Knake International security experts — Clarke from...

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Catching Up with OFAC Sanctions Enforcement Actions

Michael Volkov highlights three sanctions-related enforcement actions all breaking in the last six weeks – and two of which involved travel services to Cuba. He covers the violations, the circumstances and the penalties. OFAC is clearly sending a message about sanctions enforcement and compliance responsibilities. The agency is aggressively seeking out new targets for enforcement and continues to focus on Iran,...

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Cross-Culture: What Finance Can Learn About Compliance Culture From Volkswagen, Novartis & Tenneco

Thomson Reuters’ Henry Engler compiles guidance from the Chief Compliance Officers at Volkswagen, Novartis and Tenneco – principles that transcend their respective industries and are universally applicable. Prompt acknowledgement of internal wrongdoing and transparency over the lessons learned from conduct failures were just some of the keys to a strong corporate culture cited in a recent wide-ranging discussion on what...

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Is It Time to “Nudge” Compliance?

Recent growth in the science of behavior has introduced new tools to the compliance officer’s toolbox. Vasco Brazão and Tania Ramos of CLOO argue that, despite our best intentions to do what is right, we often fail to act accordingly. Ethical nudges can help organizations steer their employees into ethical behavior, and compliance officers should take note. Ultimately, the job...

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What Financial Firms Must Do to Mitigate the Risks of Digital Communications

Emerging technologies are complicating compliance for financial services firms. Smarsh’s Robert Cruz, an expert on information governance and regulatory compliance, shares some of the key the challenges they face, as well as a path forward. For financial firms to stay compliant, they need to meet all the books-and-records and supervisory mandates required by FINRA and the SEC. But the ever-expanding...

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Using Comedy and Creativity to Enhance Compliance and Risk Training

Entertainment and comedy can be a hugely effective way to get compliance and risk training to “stick.” Ronnie Feldman builds a business case for more creative approaches to training and communication. Let’s talk about comedy and corporate risk. Using humor and other entertaining devices to train and communicate ethics, compliance and other corporate risk topics may seem counterintuitive. After all,...

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