Global banks have been the focus of enforcement actions, focusing on AML and sanctions violations. With the new beneficial ownership regulations effective May 11, 2018, we are about to see a significant transformation in AML...more
4/19/2018
/ Banking Sector ,
Beneficial Owner ,
BSA/AML ,
Compliance ,
Corporate Governance ,
Deferred Prosecution Agreements ,
Enforcement Actions ,
Financial Institutions ,
Internal Controls ,
Money Laundering ,
Popular ,
Rabobank ,
Risk Assessment ,
Suspicious Activity Reports (SARs) ,
US Bancorp
The chief compliances officer is the guardian of a company’s most important intangible asset – its culture. Everyone at a company is responsible for a company’s culture; the board of directors, CEO, senior executives play an...more
Compliance is a dynamic subject and a profession that “never sits still.” Compliance professionals are always developing new ideas, strategies and approaches to solve problems, and increase efficiency and effectiveness. It...more
The SEC continues to exercise its powerful enforcement tool – internal controls violations – in FCPA enforcement actions against public companies. Kinross Gold Corporation is the latest company to enter into an FCPA...more
No one needs to be reminded about the importance of anti-corruption compliance. For global companies, anti-corruption risks are amongst the top 3 risks identified by corporate leaders....more
3/20/2018
/ Accounting Controls ,
Bribery ,
Compliance ,
Corruption ,
Due Diligence ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Controls ,
Securities and Exchange Commission (SEC) ,
Settlement ,
Third-Party Risk ,
White Collar Crimes
Companies have to embrace a holistic management approach to their internal controls. In the corporate governance world, a new approach is needed to develop a more rational and consistent method for managing your company’s...more
A company’s internal controls define the backbone of its operations, encompassing financial, operational and compliance functions....more
If you want to learn and read about managing third-party risks, you will have no trouble finding articles, white papers, webinars and more available to you on the Internet. And for good reason....more
The FCPA includes a specific requirement that a public company maintain an adequate set of internal controls. A company's compliance program is one component of a company's internal controls. Sarbanes-Oxley expended and...more
Wells Fargo’s ability to grow its business is on hold for a year while it designs and implements a remediation program to address deficiencies in its board governance, risk management and compliance program. ...more
2/14/2018
/ Bank Accounts ,
Banking Sector ,
Compliance ,
Consumer Financial Products ,
Corporate Culture ,
Corporate Governance ,
Cross-Selling ,
Enforcement Actions ,
Federal Reserve ,
Internal Controls ,
Remediation ,
Risk Management ,
Wells Fargo
Global companies should implement an AML program and KYC practices that follow the general outline for best practices, though it does not need to be as rigorous as a financial institution. For most companies, AML risks can...more
My final posting on this week’s ethics series is a call to action for all compliance professionals. Every compliance officer should insist on and embrace a title – “Chief Ethics and Compliance Officer.” Some larger...more
Global companies need to actively work to prevent fraud and corruption. Fraud and corruption go hand-in-hand. To commit bribery, bad actors have to gain access to money for unauthorized (illegal) purposes. A failure to...more
11/8/2017
/ Bribery ,
Compliance ,
Corporate Fraud ,
Corruption ,
COSO ,
Ethics ,
Financial Reporting ,
Internal Controls ,
Procurement Guidelines ,
Risk Management ,
Third-Party Risk ,
Transparency ,
White Collar Crimes
Chief compliance officers are politicians and have to possess great interpersonal skills. They have to “get along” and persuade key constituencies — most especially their business partners – to commit and devote time and...more
Human resources and compliance professionals share many common objectives and interests. They need to coordinate and operationalize their joint interests in a variety of ways....more
11/2/2017
/ Chief Compliance Officers ,
Compliance ,
Corporate Culture ,
Corporate Governance ,
Corporate Management ,
Ethics ,
Hiring & Firing ,
Human Resources Professionals ,
Internal Controls ,
Pre-Employment Agreements ,
Screening Procedures
A company that commits bribery has to undergo a soul-searching examination of its operations, from top to bottom. Bribery violations come in all shapes and forms – systemic violations like Siemens, Daimler and other...more
10/30/2017
/ Bad Actors ,
Banking Sector ,
Bribery ,
Chief Compliance Officers ,
Compliance ,
Corruption ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Controls ,
JPMorgan Chase ,
Sons And Daughters ,
White Collar Crimes
In Part II of my continuing series, I identify in broad strokes some of the more significant positive and negative aspects of ISO 37001. While it is easy to second-guess the ISO 37001 authors, there are some interesting...more
10/17/2017
/ Anti-Bribery ,
Bribery ,
Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Corporate Governance ,
Corruption ,
Ethics ,
Internal Controls ,
Risk Management ,
Risk Mitigation ,
White Collar Crimes
Compliance officers have to avoid complicating a compliance program. As in many areas in life, there is a value in simplicity.
Take for example a compliance training presentation. If a compliance officer overwhelms his/her...more
People are getting confused. A company’s ethical culture is not a touchy-feely concept that makes everyone warm and cozy all over. At the same time, compliance controls are not hard and fast rules that are mechanically...more
At the outset, let me concede that I am not a psychiatrist (although we all feel like one at times with family members and colleagues). My observations on CEO leadership come from my own life experiences, and professional...more
It is time for an honesty check – many CCOs do not like change. CCOs, however, need to embrace change as a powerful force. Compliance is an evolutionary process – it is constantly changing. A compliance program has to move...more
Chief compliance officers have to devote more time to establish and maintain a positive relationship with the corporate board or audit/compliance committee. CCOs have a lot of responsibilities and feel a lot of pressure to...more
We are fascinated by corporate scandals. Since the 1980s, the US public has enjoyed unraveling corporate scandals, and vilifying corporate leaders caught in the web of deceit and misconduct. I am sure there are historical...more
9/6/2017
/ Automotive Industry ,
Bank Accounts ,
Banking Sector ,
Beneficial Owner ,
Bribery ,
Compliance ,
Corruption ,
Cross-Selling ,
Ethics ,
Financial Fraud ,
General Motors ,
Internal Controls ,
National Emissions Standards ,
Product Defects ,
Telecommunications ,
VimpelCom ,
Volkswagen ,
Wells Fargo ,
Whistleblowers ,
White Collar Crimes
Compliance officers understand that a company’s greatest risks surround access to and use of money. A CCO has to understand a company’s financial controls, and in a perfect world, should have a seat at the table in the...more
In our perpetual quest for simplicity, sometimes we fail to understand the complexity of an issue. In the corporate world, if you ask board members and CEOs how they would define a compliance program ”failure,” I am sure...more