The Securities and Exchange Commission has announced a new specialized unit inside its Enforcement Division dedicated specifically to accounting and financial reporting fraud, and the announcement is worth reading closely, not just for what the unit will do, but for what its creation says about how the agency is currently defining its own enforcement priorities. A New Unit With a Specific Mandate The unit will...

Ethisphere and Ethena just released a research report that every compliance officer should read carefully, not because it breaks new ground on AI risk, but because it turns the mirror around and asks an uncomfortable question: if ethics and compliance is the function writing the rules for how everyone else uses AI, why is it the function using AI the least itself? The report, based...

I was honored to appear on The Third Party Risk Association’s Podcast, TPRM Exchange, hosted by Hilary Jewhurst, to have an interesting discussion on Sanctions Compliance. The podcast is available HERE.

Michael Peregrine and Ashley Hoff recently published an interesting article on the importance of Board Vigilance on Corporate Fraud — a copy of this insightful article is available below.

FinCEN’s $125 million penalty against UBS is notable for more than its size, though it is the largest fine ever imposed on a broker-dealer under the Bank Secrecy Act. What makes this case a critical study for compliance officers is that it is a recidivism case. UBS was fined for Bank Secrecy Act violations in 2018, and according to FinCEN’s August 3 announcement, the bank...

A federal jury sitting in Brooklyn has convicted Asante Kwaku Berko, a dual U.S.-Ghanaian citizen and former Executive Director in Goldman Sachs’ Investment Banking Division, on charges of conspiracy to violate the Foreign Corrupt Practices Act, a substantive FCPA violation, and money laundering conspiracy, following a nine-day trial. Berko later went on to serve as Managing Director of Tema Oil Refinery, one of Ghana’s major...