Compliance Tip of the Day: Rethinking Corporate AI Governance Through Design Intelligence
Compliance Tip of the Day: COSO Governance Framework: Part 4, Culture
Compliance Tip of the Day: COSO Governance Framework: Part 1, Introduction
Compliance Tip of the Day: Internal Control Deficiencies
FCPA Compliance Report: Stay the Course: Ellen Lafferty on Navigating Anti-Corruption Compliance in 2025
Adventures in Compliance: The Novels – The Hound of the Baskervilles, Introduction and Compliance Lessons Learned
Compliance Tip of the Day: Assessing Internal Controls
Key Discovery Points: BYOD Case Law Covering Subpoenas and Employee Handbooks
Compliance Tip of the Day: COSO Objective 5 – Monitoring Activities
Compliance Tip of the Day: COSO Objective 4 - Control Information and Communication
Hospice Insights Podcast - Election Inspection: Be Proactive to Avoid Costly Election Statement Denials
Compliance Tip of the Day: COSO Objective 3 – Control Activities
Compliance Tip of the Day – COSO Objective 1 – Control Environment
Compliance Tip of the Day: Code of Conduct as an Internal Control
Rethinking Records Retention
Compliance Tip of the Day: Internal Controls for GTE
FCPA Compliance Report: Revolutionizing Speak Up: Ariel D. Weindling on Enhancing Whistleblower Systems
Compliance Tip of the Day: Implementing Internal Controls
Podcast: Addressing Patient Complaints About Privacy Violations
Compliance Amidst a Global Consensus Breakdown
Since 2019, the number of users on Microsoft Teams has risen 1500%, from a modest 20 million users in the pre-pandemic year (2019) to over 320 million users in 2024. Microsoft's collaboration platform is now the default...more
Organizations whose mantra is “We just never delete anything” (i.e., organizations simply retaining all information indefinitely) are now facing headwinds, especially when the information contains personal information. As our...more
Who may be interested: Registered Investment Advisers, Registered Investment Companies, Compliance Staff - Quick Take: The SEC recently announced a number of additional enforcement actions relating to recordkeeping...more
SEC DROPS NEW REQUIREMENT FOR INCIDENT RESPONSE PROGRAMS, PROPOSAL FOR RIAS TO ADOPT CIP, SEC EXAMS SHARES MARKETING RULE FAILURES, RIA SLAMMED FOR FAILING TO RETAIN TEXTS, AND SEC WINS ON SHADOW TRADING THEORY - Welcome to...more
Who may be interested: Investment Advisers, Broker-Dealers - Quick Take: The SEC settled charges against an investment adviser for widespread recordkeeping deficiencies related to the adviser’s failure to obtain, maintain...more
The Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory Authority (“FINRA”) have, in two separate recent settled enforcement actions involving off-channel communications (“OCC”), imposed fine...more
Overview - On 3 April 2024, the US Securities and Exchange Commission (the SEC) announced the first settlement with a stand-alone registered investment adviser for, among other things, failures to maintain and preserve...more
On April 3, 2024, the U.S. Securities and Exchange Commission (SEC) announced yet another settlement regarding “off-channel communications.” As we have previously written about, settlements of this type have become...more
Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more
In light of the DOJ’s most recent guidance on the use of personal devices and third-party messaging applications by corporate personnel, this White Paper addresses issues and challenges that companies are facing in this area...more
Honestly, I have been avoiding this topic since it presents a real morass of risks and potential traps for the unwary company and Chief Compliance and Chief Legal Officers....more
Over the last several years, the Securities and Exchange Commission (the “SEC”) and the Commodities Futures Trading Commission (“CFTC”) have been laser-focused on the use of so called “off-channel communications” in the...more
As a number of recent headlines demonstrate, the U.S. Securities and Exchange Commission (SEC) and other regulators have fined and penalized employers and employees in the financial services industry for non-compliance with...more
The U.S. Department of Justice (DOJ) recently released new guidance announcing several policy changes to further strengthen and clarify its approach to prosecuting corporate crime. The guidance, released through a memorandum...more
Recent reports indicate that the Securities and Exchange Commission (SEC) is increasing its attention on registered investment advisers (RIAs) and their oversight and recordkeeping responsibilities related to employees’ use...more
On September 27, 2022, the Securities and Exchange Commission (“Commission”) entered into a series of settled orders (“Orders”) against 15 broker-dealers and one affiliated investment adviser for widespread failures by the...more
An investment management company was recently hit with $200 million in fines for failing to track employees’ use of personal messaging apps, which resulted in the loss of communications that were subject to regulatory...more
The rules and regulations governing private equity and hedge fund advisers continue to develop in response to changes in technology, particularly in the areas of social media and cybersecurity. As a result, advisers become...more
When you need information, where do you go? For the majority of people today, the answer involves a smartphone and social media. From Facebook and LinkedIn to Instagram, Twitter, and even YouTube, social media is...more
• On December 14, the SEC’s OCIE issued a Risk Alert summarizing the findings of its limited-scope examination initiative relating to electronic messaging. • Noting a “pervasive use” of electronic messaging by adviser...more
On October 16, 2018, the SEC issued a 21(a) report announcing that it had investigated whether certain public companies that were victims of oftentimes unsophisticated, cyber-related frauds had violated federal securities...more