Corruption, Crime & Compliance

Featured Articles:

26 Aug, 2019

The Current State of Compliance and Internal Audit Partnership

Compliance officers and internal auditors are natural partners and allies in the compliance governance landscape. As the compliance profession and influence grew, compliance officers often leaned on internal auditors for help in assessing risks, uncovering financial misconduct, and assessing compliance functions and controls. Recently, however, I have noticed some changes in their relationship, suggesting that they both are maturing and gaining independence from each other. ...

General

25 Aug, 2019

Attend Converge19: October 1 – 3, 2019

Converge19 is scheduled for October 1 to October 3, 2019. I am proud to participate in the event and scheduled to speak on OFAC Sanctions Compliance. If interested in attending, please sign up here. The Agenda is here. CONVERGE19 is in its 4th year of bringing together the world’s leading companies for 2 days of dynamic speakers, thought-provoking breakout sessions, and opportunities to connect with...

Podcasts

25 Aug, 2019

Episode 105 — Third-Party Risk Management: Interview of Bill Hauserman and Ted Datta, Bureau van Dijk

Listen to Episode 105 HERE. Bill Hauserman and Ted Datta from Bureau van Dijk, a Moody’s Analytics Company, join us for an interesting discussion on third-party risk management, issues surrounding beneficial ownership, trends in the industry and the importance of validating ownership and data quality. Bill and Ted explain their interesting perspective on third-party risk challenges, regulator expectations and a fascinating view from the global...

General

21 Aug, 2019

Putting Data Security Risks in Perspective: The Proper Role of a Chief Privacy Officer

This is likely to be a politically incorrect posting. I hope I do not offend too many people, especially those new data privacy professionals. As kids, we were always excited when an ice cream truck visited our neighborhood offering a new flavored ice cream. For a brief period of time, the new ice cream flavor was the popular rage. In the corporate legal and compliance...

General

20 Aug, 2019

Key Actions to Ensure Compliance with the California Consumer Privacy Act (Part II of II)

The California Consumer Privacy Act (CCPA) presents numerous compliance challenges for businesses. Given the heightened focus on consumer privacy and ever-increasing enforcement risks, companies have to move quickly to ensure appropriate compliance programs are in place by January 1, 2020. Any business that collects, stores and processes consumer information is subject to significant risks. The importance of CCPA compliance is not limited to businesses that...

General

19 Aug, 2019

California Sunshine — The California Consumer Privacy Act (Part I of II)

When the federal government fails to assume responsibility for establishing law and policy in important federal areas of jurisdiction, the individual states then spring into action to fill the vacuum. When the Framers considered the proper role of the federal government after the debacle of the misguided Articles of Confederation, the Framers adopted our Constitution premised on the foundation of a strong federal government. Unfortunately,...

Podcasts

18 Aug, 2019

Episode 104 — Deep Dive into Microsoft FCPA Settlement

On July 22, 2019, Microsoft finally resolved its FCPA enforcement action with a whimper. Notwithstanding prior suggestions that Microsoft’s investigation uncovered global conduct, Microsoft’s liability focused primarily on Microsoft’s conduct in Hungary. Even with the tailored settlement agreement, DOJ and the SEC reiterated robust expectations surrounding third-party distributor networks, particularly in the software industry. To resolve a lengthy six and one-half year investigation, Microsoft entered into a non-prosecution...

General

15 Aug, 2019

OFAC Implements Broad Sanctions Against Venezuela

In a major announcement and escalation of the sanctions regime targeting President Maduro and Venezuela, on August 5, 2019, the Trump Administration issued a new Executive Order 13884 (Here) to block all property of the Venezuela Government. The aggressive action was implemented to target the Maduro regime. At the same time, OFAC issued 12 amended general licenses (Here) and 13 new general licenses (Here), and...

General

13 Aug, 2019

Cybersecurity Threats, Data Privacy and the Important Role of Compliance

Most compliance officers will admit that they have more than enough responsibilities in their purview. They are usually not looking for more. I have some bad or good news on this front depending on your perspective. As companies struggle with cybersecurity and data privacy issues, companies should naturally turn to compliance to play a larger role in overall risk mitigation strategies. Up to now, it...

General

12 Aug, 2019

OFAC Announces $1.7 Million Settlement with Truck Manufacturer for Violations of Iran Sanctions Program

In yet another enforcement action, OFAC announced a $1.709 million settlement with PACCAR, Inc., for 63 apparent violations of the Iran Sanctions Program by DAF Trucks, a wholly-owned subsidiary based in Eindhoven, Netherlands. (Here). On three separate occasions, between October 2013 and February 2015, DAF sold or supplied 63 trucks to customers in Europe that it knew or had reason to know were ultimately intended...