Companies leave a trail of breadcrumbs when they design and implement practices that lead to an ethical culture. Jay Rosen explains how following that trail can be part of the monitoring process. In this final part of my series on corporate culture, I will consider how ethical culture is a part of an overall ethics and compliance program assessment and...
Federal contracting can be lucrative and rewarding – when done correctly. Steptoe & Johnson’s Fred Geldon outlines the various requirements contractors face in the government marketplace. Doing business with the government is different. The federal government makes rules to protect the public interest and the public treasury, waiving enough of its “sovereign immunity” so that contractors will elect to do...
Clifford Chance’s Wendy Wysong and Nick Turner discuss the sanctions risks looming in Hong Kong and what companies operating there can do to protect themselves. with co-author Nick Turner The Financial Action Task Force (FATF) issued its much-anticipated Mutual Evaluation Report (MER) of Hong Kong on September 4, 2019. Among its recommendations, the MER encouraged Hong Kong to closely monitor...
Compliance officers’ responsibilities are growing, and keeping pace with a fast-changing landscape is becoming increasingly difficult. Smarsh’s Shaun Hurst points to a need for CCOs to adopt a new mindset. Chief Compliance Officers (CCOs) have earned their rightful seat at the C-Suite table; no business strategy today can succeed without first addressing the ongoing threats of shifting regulations and newly...
The deadline recently came and went for the DOJ to finally offer clarity on the issue of ADA website compliance. Fortis Law Partners Liz Hartsel discusses how the DOJ’s nonresponse could lead to an increase in litigation. On August 30, the U.S. Department of Justice faced a congressional question-and-answer deadline regarding a costly and ongoing litigation risk for American businesses. Senators had pressed the U.S....
How to avoid fraud and corporate crime (while improving compliance programs) from Rafael Aguilera Gordillo, professor of Corporate Compliance and International Security. Increasingly complex economic crime is jeopardizing justice in general and criminal law in particular. On many occasions, there are issues with effectively facing the questions and difficulties posed by corporate criminality and white-collar crime. For this reason, "traditional"...
Jay Rosen concludes his series on monitoring in health care with a consideration of how using an independent integrity assessment and monitoring can minimize negative impacts. Many compliance practitioners in the health care space (and those in commercial space) often ask if an independent integrity review and monitoring would be helpful where an organization may have reason to believe it...
Many organizations struggle with the payment Card Industry Data Security Standard. Lockpath’s Dennis Keglovits outlines what organizations can do to get ready for the requirement now and to maintain compliance with PCI DSS going forward. The Payment Card Industry Data Security Standard (PCI DSS) is a requirement for any entity storing, processing or transmitting customer cardholder data; essentially designed to...
Public companies based in the U.S. are choosing the less onerous (but riskier) of two possible methods for complying with new standards for recognizing revenue from customer contracts. This two-part series from Intelligize explores the new rules and provides insights for public companies subject to the new standards. Nearly 12 years in the making, the new rules cut across all...
Cowden Associates CEO Elliot Dinkin discusses the liability health care organizations assume when enlisting the services of a “business associate” and shares a couple of cautionary tales that make clear why third-party due diligence is so critical. Businesses with access to patient health data risk Health Insurance Portability and Accountability Act (HIPAA) violations that can lead to steep federal and...
SEI’s Kevin Byrne on why it’s imperative for firms to consider how they use data if they want to remain competitive. Clean capture is crucial, as is flexibility to adapt to a continually changing security environment. It seems the answer to every question recently has been “more data.” As our data pools grow, so too must our technological capabilities to...
Establishing a sustainable preservation plan is key for compliance and risk management. Onna’s Ish Alaoui outlines five key factors to weigh when looking to preserve data from cloud-based applications. The number of cloud-based applications and productivity tools used in the workplace is growing by the day. From Slack and GSuite to Dropbox and Office 365, today’s top workplace applications allow...
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