How the CEO Can Best Support Compliance Keeping a tight rein on compliance is the name of the game for every business entity, whether early-stage, family-owned or large multinational. And – while it’s the CEO who ultimately sets the tone – the culture of compliance has a strong foundation in the company’s code of ethics and its business conduct. One...
With contributing authors Ali Burney and Nicholas Turner The Office of Foreign Assets Control has just levied a penalty against Exxon Mobil for executing several agreements with Russian oil company Rosneft. The company itself wasn’t the sticking point, though; the agreements might have been fine had they not been signed by Rosneft’s President, who’s recognized by the U.S. as a...
Leveraging COSO’s Internal Control – Integrated Framework Cultures may vary widely, but all organizations should be proactive about building and maintaining a culture of compliance. The COSO Integrated Framework provides extensive guidance on how to accomplish this. Ron Kral offers insights on integrating your company’s C&E program with a control framework. While many organizations have a compliance and ethics program...
How the CEO Can Support Compliance Many executives view compliance as a “check the box” proposition. In this column, LeClairRyan attorneys Brian Lansing and Patrick Hurd argue that a focus on compliance should permeate the entire organization, in much the same way that Amazon obsesses about customer service. It all starts at the top, with the CEO setting the tone....
A Much-Needed Intelligent Approach to Segmentation Anti-money laundering (AML) is a complex and persistent challenge for financial institutions. AI is transforming key elements of the AML workflow and delivering an order of magnitude in performance improvements in the process. Money laundering has become the leading source of compliance fines for North American and European institutions. In 2016 alone, regulators levied...
Here’s How They’re Failing The relationship between compliance officers and the company’s top leadership is a hot one these days, and there are specific ways CEOs can be more effectively supporting compliance practitioners. It’s a complex relationship, but one bears improving in many cases. Avani Desai offers insights into just what executives can do better. When speaking with CEOs and...
How Much Reliance on Technology is Too Much? The last few years have seen a significant rise in regtech, technological solutions for compliance. These solutions can be hugely helpful to companies as their compliance burdens increase in scope and complexity, but they certainly don’t absolve organisations of the responsibility of fostering a culture of compliance. with contributing authors Jenni Hill,...
A Compliance Officer’s Role in Mitigating This Risk Mobile computing presents a unique set of challenges to compliance officers. Our devices are truly omnichannel and not just dedicated to one aspect of our lives. No organization can be fully compliant with data protection regulations when its staff carry personal devices with sensitive information on them; many of these devices are likely...
What Does This Mean for You? The Department of Justice (DOJ) has increasingly been using pretrial diversion programs, which often take the form of deferred prosecution agreements (DPAs) and non-prosecution agreements (NPAs), as a tool to hold corporations accountable for wrongdoing. with co-author Briannon Irwin The Department of Justice (DOJ) has increasingly been using pretrial diversion programs, which often take...
Landmark Decision on Criminal Liability In the ongoing, global fight against corruption, it appears the gloves are coming off. Charges were leveled against the acting director of Kassar Logistics and World Eastern International for his negligence in incorporating the companies despite evident fraudulent activity. Wendy Wysong and colleagues from Clifford Chance detail the sentence and offer advice for directors and...
The Opaque Nature of Ownership As regulation around global business relationships increases in importance, it’s critical for enterprises to know the true owner of the businesses they are working with. Brian Alster of Dun & Bradstreet describes the opaque ownership structure that many businesses often implement and strategies companies can adapt to find out true beneficial ownership of businesses. While...
What Business Owners Need to Know as Governments Outsource Code Enforcement Companies across virtually every industry are experiencing a rapid increase in regulation. Naturally, regulatory agencies are having a hard time keeping up with enforcement. That being the case, some state and local governments are turning to private companies and outsourcing enforcement. Compliance is always in a company’s best interest,...
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