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Building a Defense-in-Depth Culture to Combat Phishing
Phishing attempts are only growing more sophisticated by the day, and effective cybersecurity means defending all the vectors of attack, particularly the human ones, as they’re the most vulnerable. KnowBe4’s Perry Carpenter talks about establishing a defense-in-depth strategy and how it starts with your culture. Phishing has been around for decades, but it continues to...
Harnessing the Power of the Pause
In our hyper-connected world, it’s easy to push our human need for peace to the back-burner. But a well-being practice isn’t just about active mindfulness; it’s also about embracing stillness. It seems like 2023 began with a burst of energy. There are taxes to be filed, programs to be assessed, momentum and lift achieved. In...
What Is Safe in a World Without Antitrust Safe Harbors?
A trio of policy statements dating back to 1993 established the concept of safety zones with regard to information exchanges and antitrust laws. But now that the DOJ has rescinded that guidance, the waters around safe harbors are decidedly murky. Fiona Schaeffer and Adam Di Vincenzo of Milbank dive into these developments. For decades, a...
Many Businesses Say DEI Is a Core Value, But Are They Following Through?
Former employment attorney and entrepreneur Erika Royal challenges companies to get real on DEI and offers some actionable steps to get them started. An estimated 80% of U.S. employers have DEI initiatives underway, but a much smaller share of business leaders truly understand how to effectively implement DEI strategies in their workplaces. DEI has the...
Sharing Is Caring? Lessons From Dutch Banks’ Data-Sharing Program
With federal investigations pending, the autopsy of Silicon Valley Bank and resulting cascade of bank failures is only just beginning. Experts have suggested a faulty risk model is partially to blame, and while sharing customer data with its peers likely would not have saved the bank, business data analyst Sukirt Singh suggests SVB and other...
AML & KYC: Addressing Key Challenges for 2023 and Beyond
(Sponsored) In today’s world, financial criminals are often a step ahead of regulators and financial institutions who struggle to effectively guard against the threat of money laundering and financial crime. It was once estimated by the International Monetary Fund (IMF) that money laundered throughout the world on an annual basis can be up to 2%...
IIA Survey: Technology Issues Widening Risk Landscape
The past year has seen internal audit staffing and budgets continue their recovery to pre-pandemic levels as organizations contend with an increasingly broad risk landscape, according to new research from the Institute of Internal Auditors (IIA). IIA’s 2023 North American Pulse of Internal Audit survey found that technology was a primary driver of risk, including...
As Layoffs Continue, the Potential for Insider Fraud Is Growing. Are You Ready?
From startups to big banks, the technology and financial services sector have already seen tens of thousands of layoffs in 2023. Not only do these cuts challenge main business functions, but they could lead to serious trouble down the road in the form of insider fraud. Bottomline Technologies’ Chris Gerda talks about new approaches banks...
Fraud Section’s 2022: A Year of Individual Accountability, Cooperation With Foreign Authorities & Pushing Compliance Programs
The DOJ’s Fraud Section had a banner year in 2022, posting its highest number of convictions in a single year — 56 — and continuing the agency’s stated focus on individual accountability. Sandra Moser, Justin D. Weitz and Erica A. Jaffe from Morgan Lewis unpack the agency’s annual report. In recent years, the number of...
Sales at All Costs? Unified Credit Risk Management Can Squash Bad Deals Before They Happen
The collapse of a business doesn’t usually happen all at once. There are warning signs. Late payments, legal filings and falling credit scores are all flashing red lights that something bad is coming. That goes for your customers, too, but risk information is often siloed. Creditsafe’s Matthew Debbage unpacks some findings of his company’s recent...
It Takes a Village: Preventing FinCrime Means Everybody Needs Skin in the Game
Banks bear the brunt of consequences for financial crimes amid a huge increase in anti-money laundering fines in 2022, making them an easy target when financial crime is suspected. But fighting fincrime isn’t the sole responsibility of banks, argues Samar Pratt of Exiger in London, who says a flawed approach allows financial crime to persist...
From Regulation to Volume, There Is No Light at the End of the Data Privacy Tunnel
Data proliferation and data privacy regulatory activity across the globe have created the need for focused boardroom discussions. An underpinning to such discussions is the inextricable link between data privacy compliance and information security. Protiviti’s Jim DeLoach shares eight questions companies need to answer in their pursuit of data privacy compliance and best practices. While...
UK Resurrects Data Protection Reforms, EU Court Rules on GDPR in Civil Cases
Recent courtroom and legislative action in Europe will likely have ripple effects around the world for companies subject to regulations like the UK and EU GDPR. Jonathan Armstrong and André Bywater of Cordery explore the developments. Last year, the UK government introduced a legislative proposal to change the UK privacy/data protection regime (which essentially consists...
Everything You Need to Know About pKYC
Simply knowing your customer isn’t enough anymore; to keep pace with modern threats, perpetual know-your-customer practices will enable organizations to manage risk. Moody’s Keith Berry tells companies everything they need to know about pKYC and argues for a mindset-shift in many organizations. Organizations have to protect themselves from fluctuating risk levels and new financial crime...
Corporate Enforcement Policy Updates: A Spoonful of Sugar or Just More Medicine?
By adding incentives to encourage self-disclosure of corporate misconduct, the DOJ signaled a major change in its approach. And while many of the changes are welcome, Blank Rome’s Inbal P. Garrity and Amelia Clegg wonder if the revisions are sweet enough. The DOJ’s Criminal Division may not have had a change of heart when it...
A Bot Isn’t Going to Take Your Place, But AI Will Make Your Job Harder
OpenAI’s splashy ChatGPT rollout has generated untold amounts of text, both directly and indirectly. While much of what’s been written so far has been about creative work, which some fear will be completely upended by ChatGPT, CCI’s copy chief, Jennifer L. Gaskin, looks at how generative AI tools will change the corporate integrity landscape. Like...
New DOJ Guidance Charts a Way Forward on Ephemeral Messaging
New guidance from the DOJ on what makes an effective compliance program should be mandatory reading for every corporate integrity professional. Living Your Best Compliance life columnist Mary Shirley shares her thoughts on upshots of the new guidance. This month kicked off with an exciting development for informing corporate compliance programs, the release of an...
Activision Settlement Highlights Where Companies Often Go Wrong With Whistleblowers
The SEC has long relied on whistleblowers to enforce securities law, often making it worth their while to the tune of as much as 30% of a monetary sanction. Attorney Katherine Krems shares her insights on how Activision’s recent SEC settlement provides a lesson in what not to do. On Feb. 3, the SEC announced...
Survey: 1 in 3 In-House Legal Teams Don’t Have DEI Strategy
In many organizations, diversity and inclusion efforts are enterprise-wide, but a survey by legal and compliance recruiter BarkerGilmore found that most companies aren’t using broad strategies to increase the diversity of their in-house legal teams. Still, despite the fact that about 37% of those surveyed say their companies have no strategy in place regarding DEI...
Uncharted Waters: McDonald’s Case Ushers in New Era of C-Suite Accountability
A C-suite title on your business card doesn’t just come with a cushy corner office. Since January’s blockbuster Delaware Chancery Court decision regarding toxic behavior at McDonald’s, it could also mean that you’ll bear the same oversight duty traditionally reserved for members of the board of directors. Bart M. Schwartz of Guidepost Solutions is currently...
Preparing for Budget Cuts in 2023? Be Sure Personnel Management Isn’t on the Chopping Block
For compliance departments that need to do more with less, it’s tempting to lean into automated systems. Compliance and ethics consultant and author Vera Cherepanova warns that focusing on numbers — and not people — can cause more damage in the long run. With compliance teams around the world dealing with cost-cutting edicts from their...
How Small Financial Institutions Need to Handle ESG — Today and Tomorrow
Facing a potential recession and anti-ESG headwinds may have smaller financial institutions thinking about budget cuts aimed at sustainability efforts. FTI Consulting’s Evelyn Basham and Enrique Ubarri explore what small and mid-sized banks and other financial institutions need to know about ESG in 2023 and beyond. Financial institutions of all sizes are in the midst...
1-2-3s of ABAC Compliance Programs
Despite the proliferation of laws aimed at fighting bribery and corruption, a recent international report found that most countries are failing to stop corruption. How can organizations ensure they’re doing their part? Certa’s Jag Lamba offers nine signs that your company’s ABAC program is on the right track. Anti-bribery and anti-corruption (ABAC) laws and standards...
The Global (Mis)alignment of Human Rights Sanctions
There's no shortage of measures designed to safeguard human rights across the globe, but Washington, London and Brussels have yet to fully see eye-to-eye on what entities to target. Vincent Gaudel from LexisNexis Risk Solutions sets the stage for what to expect in the evolution of thematic human rights sanctions. Combating human rights violations and...
Cloud Security Isn’t Just on Your Provider; It’s Your Job, Too
Organizations want to embrace all the benefits the cloud has to offer while still protecting their sensitive data. Engaging a cloud provider who practices security by design is a good first step, it’s far from the first one. Greg Tatham and Anthony Oliveri from Wolters Kluwer share their insights. Cloud-enabled computing has emerged as an...
A Lesson in Kindness and Appreciation From Air New Zealand
For her latest Living Your Best Compliance Life column, Mary Shirley talks about how making expressions of gratitude part of a regular practice can encourage colleagues to live up to their full, ethical potential. Air New Zealand is my home country's national airline. It is known for creative and entertaining safety videos, as well as...
Tiny Steps Can Have a Big Impact
We know change doesn’t come easy, which is why making sweeping declarations doesn’t usually work. But where big changes often prove too challenging, bite-sized ones can have a big impact. Last column we spoke about setting themes for the year ahead rather than resolutions. While it is important to have a general guide to what...
Tracking Down Emissions When They’re Buried in Your Supply Chain
Manufacturers are pressed from all sides to prove their environmental bona fides, but given the nature of manufacturing-related emissions, that means making sure their global supply chains are environmentally conscious. Assent’s Sarah Carpenter digs into her company’s recent survey of manufacturers, the pressures these companies are facing and what they can do about it. ESG-related...
Shifting Sands: Leaders Are Feeling the Pressure of an Uncertain, Dynamic Risk Landscape
The global risk landscape has rarely been more unsettled over the past half-century than it is right now, and a survey of business leaders shows most of them expect the pace of change to continue — or accelerate. Protiviti’s Jim DeLoach digs into the survey results and offers advice for surviving the storm. From the...
Worried About FTC Crackdown on Noncompetes? Start With Assessing Your Existing Contracts.
A proposal by the FTC to ban noncompete agreements in employment has been widely criticized by business groups, with the U.S. Chamber of Commerce threatening a lawsuit if it goes into effect. But, as Seyfarth Shaw’s Robert Milligan discusses, the potential noncompete ban is just the latest in the agency’s self-described crackdown over what it...