Part of a Board of Directors’ mandate is to know about the content and operations of a company’s ethics and compliance program and to have “reasonable oversight” of its implementation and effectiveness. For Compliance Officers, two concerns immediately come to mind. First, what information does the Board of Directors need to ensure that they are “knowledgeable” about the program? Second, what constitutes “reasonable oversight”? Host Michael Bramnick and LRN colleagues Keith Read and Wayne Brody discuss the answers to both – and the timing for letting the board know about a compliance concern.
Responding to BSA/AML Enforcement: Don’t Make Matters Worse with a Shoddy Action Plan
Facing BSA/AML enforcement, a financial institution’s action plan can either ameliorate or aggravate penalties. Professionals from Deloitte’s anti-money laundering and...
