Companies interact with a large number of entities in the outside world – customers, third party intermediaries and vendors and suppliers to name the most significant ones. These relationships are the lifeblood of a company....more
The corporate compliance function is only as successful as its partnerships with key internal constituencies. Depending on the company and the personnel involved, compliance has to establish and maintain effective working...more
9/29/2016
/ Anti-Corruption ,
Anti-Money Laundering ,
Antitrust Provisions ,
Code of Conduct ,
Compliance ,
Corporate Culture ,
Corporate Governance ,
Corporate Misconduct ,
Cybersecurity ,
Economic Sanctions ,
Ethics ,
Export Controls ,
Hiring & Firing ,
Human Resources Professionals ,
Internal Investigations ,
Policies and Procedures ,
Popular ,
Regulatory Standards ,
Risk Management
Forgive me for overusing the term “convergence” but when the shoe fits, I say “wear it.” If you are managing corporate risks and responsible for securing export licenses, ensuring that you are complying with OFAC sanctions...more
The New York DFS finalized its new AML and Sanctions screening regulations.
Interestingly, the NYDFS backed off its original proposal to require a Chief Compliance Officer to certify to a compliance “finding” that the...more
7/21/2016
/ Anti-Money Laundering ,
Banking Sector ,
Banks ,
BSA/AML ,
Certification Requirements ,
Chief Compliance Officers ,
Compliance ,
Cooperative Compliance Regime ,
Covered Entities ,
Economic Sanctions ,
NYDFS ,
Office of Foreign Assets Control (OFAC)
With the rise of OFAC Sanctions enforcement and compliance issues, companies have to devote significant resources to following changes in OFAC Sanctions. Over the last few years, the US government has significantly altered...more
7/8/2016
/ Bureau of Industry and Security (BIS) ,
Burma ,
Compliance ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Sanctions ,
Financial Institutions ,
Foreign Subsidiaries ,
General Licenses ,
Iran Sanctions ,
ITSR ,
Myanmar ,
Office of Foreign Assets Control (OFAC) ,
Parent Corporation ,
Physical Presence Test ,
Popular ,
SDN List
The resurgence in anti-money laundering enforcement in the last few years reflects the overall improvement in the banking industry and recovery from the financial collapse. Federal prosecutors and regulators have renewed...more
In case you are not following all the latest scandals – Unaoil and the Panama Papers being two significant ones – we are seeing an evolution and possibly a revolution in due diligence expectations....more
Financial institutions have been pushing back hard on FinCEN’s proposal to require banks, investment banks and other financial institutions to identify beneficial owners of account holders. As time goes on the impact of...more