Cybersecurity law is a patchwork of global statutes and regulations. Unfortunately, Congress has failed to act in this area, leaving the EU and US States to “lead.” As a result, companies are often required to follow the lowest (or highest) common denominator, depending on your perspective. At the US federal level, we have specific industries that have requirements for protecting sensitive personal information. The Health...
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Global companies are getting compliance overload, especially when it comes to third party risks. As we have seen over the years, third-party risk management involves significant risks on anti-corruption, AML, fraud, sanctions, human trafficking and a host of other threats to a company’s reputational standing. But that is not all – you have to add cybersecurity to the list of third-party risk management issues. Why?...
When you survey business leaders on significant risks, they invariably cite cybersecurity as number one and anti-corruption as number two. For global businesses, this makes total sense. Cyber-crime damage is estimated to hit $6 trillion annually by 2021, according to a study by Cybersecurity Ventures (here). Information security and prevention are now required to protect a company from serious financial and operational harm. We are...
Companies are correctly focused on cybersecurity risks. Notwithstanding this focus, companies are struggling with how to respond to threats and risks. Cybersecurity threats are quickly evolving – akin to the time when countries engaged in military arms races. As they evolve, companies have to embrace proactive strategies and cannot rely on a compliance strategy that reacts to events and threats. Cyber criminals are quickly embracing...
Our goals can only be reached through a vehicle of a plan, in which we must fervently believe, and upon which we must vigorously act. There is no other route to success — Pablo Picasso The chief compliance officer is at an important professional juncture – 2018 is an important year for the profession. In this era of growth, and after corporate tax relief, companies...
It is rare these days for Republicans and Democrats to agree on political priorities – another profound grasp of the obvious. Recently, on Capitol Hill there appears to be some common ground on the issue of reforming AML laws and regulations. The motivation is to make financial AML regulations “smarter” and increase focus on beneficial ownership, terrorist financing and proactive detection of money laundering. Some...
Compliance officers are a much more collaborative group of professionals than lawyers. Compliance officers share information with colleagues about compliance experiences, best practices and strategies. The compliance industry benefits from this sharing of information. On occasion, however, this sharing of a company’s performance in one area can lead to unfair judgments by a recipient of the information. For example, one company may conduct an in-depth...
Regulators and enforcement agencies continue to pursue aggressive regulations and requirements for financial institutions (a very broad definition under Title 31 of the US Code and regulations). The new administration does not show any signs of altering the course of agency priorities. Money laundering, sanctions and securities enforcement has continued at a straight-forward pace from the Obama Administration. The most significant upcoming development is FinCEN’s...
Financial institutions face enormous pressures with respect to anti-money laundering compliance. These burdens are about to grow with implementation of customer due diligence rules. In 2017, federal and state regulators stepped up AML enforcement. Here is a quick rundown of some of the enforcement actions: Citibank paid a $70 million penalty to the Office of the Comptroller of the Currency (here) for violating its 2012...
