Tagged: Chief Compliance Officer

21 Jul, 2015

Webinar: Managing Private Equity Corruption Risks

Date: Tuesday, August 11, 2015 Time: 12 Noon EST Sign Up Here Justice Department and SEC prosecutors are devoting greater attention to private equity FCPA enforcement. This coincides with increased SEC regulation and examination of the private equity industry. Private equity companies face significant corruption risks in global markets. From sovereign wealth funds to portfolio companies, private equity compliance officers have to design and implement...

General

20 Jul, 2015

Leveraging a Global Compliance Network

Multinational companies cannot employ and maintain a sufficient number of dedicated compliance staff to ensure the effectiveness of an ethics and compliance program. That is a reality and we all know that is true. Instead, global companies have to figure out ways to leverage other personnel from other functions to serve as some part of a global compliance functions. This regularly occurs with respect to...

Events

20 Jul, 2015

LexisNexis CLE-Eligible Webinar: A Holistic Approach to Due Diligence and Third-Party Risk Management

Date: August 6, 2015 Time: 2 pm – 335 EST Sign Up Here Many companies have implemented robust due diligence vetting, monitoring and auditing strategies for managing third-party risk. No due diligence system is foolproof in identifying high-risk business partners or predicting which partners will engage in bribery. Join Michael Volkov and Richard Bistrong as they discuss how due diligence systems and monitoring and...

General

19 Jul, 2015

Refining a CCO’s Reporting Relationship to a Corporate Board

You can observe a lot by just watching – Yogi Berra There is way too much time being spent on esoteric arguments about corporate board reporting responsibilities for Chief Compliance Officers. Let’s agree and move on to more important and difficult issues. I hate to be dogmatic but when it comes to this issue, there really is one obvious solution. Varying alternatives are less than...

General

15 Jul, 2015

4 Signs of a Weak Culture of Compliance and Ethics

We all know the importance of promoting a culture of compliance and ethics. The benefits of an ethical culture are substantial and worth every penny of investment in creating and promoting such a culture. We do not need to spend time justifying why an ethical culture is important to company financial success – it is critical for corporate sustainability and profitability. Not every company has...

General

14 Jul, 2015

Rolling the Dice: Casinos, FinCEN and AML Compliance

FinCEN has many important responsibilities but one of its more interesting assignments is oversight of anti-money laundering compliance by casinos (and card clubs). Casinos are under increasing scrutiny these days for lax AML compliance. In March 2015, FinCEN imposed a $10 million penalty on Trump Taj Mahal in Atlantic City, New Jersey, for violations of the Bank Secrecy Act (BSA). In addition to this hefty...

General

14 Jul, 2015

Scrutinizing Third-Party Payments

It is often hard to convince people that receiving money can be a problem. Everyone likes to receive money, especially when they are being paid for something they did. In the area of compliance priorities, companies do not normally treat third-party payments as a high-risk activity. However, with increasing focus on illicit proceeds and tightening of AML/Terrorist Financing requirements, companies have to focus on this issue....

General

9 Jul, 2015

Know Your Customer (“KYC”) Due Diligence Best Practices

Financial institutions have a lengthy list of Anti-Money Laundering compliance requirements. They face a mountain of risks from a large number of financial transactions, each of which can carry significant risks. AML compliance programs are built on a systematic review of a large number of financial transactions. The focus of this review has to be on triggers that identify suspicious transactions or customers. Know Your...

General

8 Jul, 2015

AML Risk Assessments

I am a strong proponent of conducting a risks assessment as part of an overall ethics and compliance program. However, I often caution companies to balance benefits and costs, and not to conduct a glitzy, high-priced risk assessment. Instead, I encourage companies to conduct a cost-effective risk and compliance program assessment that focuses on risk, mitigation of such risks and measurement of residual risks. Too...

General

6 Jul, 2015

AML Risks and Compliance for Non-Financial Institutions

Consider yourself lucky if you work at a company that does not fall within the Title 31 of the US Code definition of a “financial institution.” I am being somewhat dramatic but it is important for every company to have an anti-money laundering compliance program. My suggestion is not designed to promote business or even “scare” companies into addressing this issue – it makes sense...