Tagged: risk management

The Demand for Sustainability and Risk Management

The COVID-19 pandemic uncovered the fragility of business operations – within the space of weeks, companies were forced to adjust to distribution channel and supply chain disruptions, workplace closings, and a virtual standstill in global trade.  The global economy came to a screeching halt.  While the economy is slowly recovering and poised for increased activity, consumers and investors have discovered the importance of organizational sustainability. ...

CCOs and Expertise in Risk Management

Chief compliance officers (CCOs) are talented professionals.  As Donna Boehme always emphasizes, CCOs are subject matter experts (SMEs) in compliance risks, controls and mitigation.  CCOs focus on legal and compliance risks as reflected in an organization’s Code of Conduct, ethical culture and legal requirements.  In recognition of their unique role in every organization, CCOs have line of sight across the organization, independence and authority to...

Webinar: Leverage Due Diligence to Improve Enterprise-Wide Risk Management

Tuesday, March 16, 2021 1 PM EST/10 AM PST Sign Up Here When it comes to risk, you don’t know what you don’t know. And, in some cases, you don’t know what you do know. The latter can describe the current state of third-party risk management. This session will explain how to create a forward thinking risk management program that identifies and incorporates all the risk information...

OCC Fines JP Morgan Chase $250 Million for Deficient Internal Controls

Banking regulators have been flexing their muscles.  With the coming Biden Administration, this may portend the beginning of a new, enforcement wave.  Some have suggested that banks are resolving these cases before a more aggressive approach is taken by the new Biden Administration. Citigroup recently was tagged for $400 million by the Treasury Department’s Office of the Comptroller of the Currency (OCC).  The OCC also...

Retaining a “Risky” Third-Party

Every company has done it. Chief Compliance Officers have had to hold their respective noses and push forward with due diligence to retain a risky third party. Rather than reject the third party, a CCO convinces him or herself that the company can mitigate the risks by contract representations and warranties, annual certifications, and a plan to monitor and audit the third party in the...

When Diligence is Not Given its “Due”

I find myself quibbling with compliance terms – hyper focus on small issues is not a positive trait. I often urge clients and colleagues to focus on issue of more significance and leave the smaller ones for another day. Hence, my recent criticism over “due diligence” policies and procedures for third party intermediaries. A more appropriate title is “risk management.” A due diligence inquiry of...

Third Party Risk Management Not Just Due Diligence

The term “due diligence” is an overused expression in the compliance world. It has become a term to mean heightened concern or investigation. No one can really define what it means except to say it has different meanings in different contexts. Some would say it is a term of art in the legal and compliance world. It is misleading to add the term “investigation” to...

Webinar: Cutting Edge Issues in Third Party Risk Management

July 26, 2016, 12 Noon EST Sign Up Here Global companies continue to elevate their due diligence and audit programs to mitigate third party risks. With the advent of new technology platforms and improved information collection products, global companies need to “stay ahead of the curve” when it comes to managing third party risks. Global companies face a variety of third party risks depending on...

AML Risks and Foreign Correspondent Banking

With the Panama Papers scandal and government promises of continued aggressive AML enforcement, financial institutions face a variety of risks that require increased vigilance and mitigation strategies. One of the most challenging risks facing all financial institutions is foreign correspondent banking. In essence, a foreign correspondent banking relationship is built on the effectiveness of a foreign bank’s AML compliance program and ongoing monitoring capabilities. Such...

Global Construction and Corruption

With increasing focus on infrastructure projects and greater public demand for improvements, governments are preparing to ramp up construction projects. Part of the budgeting process has to acknowledge the cost of corruption. It does not take a rocket scientist to figure out that construction and corruption go hand-in-hand. Corruption occurs in construction projects because of the incendiary mix of money, government bureaucracy, and lack of...