AI and the False Claims Act
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
The Financial Conduct Authority's (FCA) long-awaited new measures for tackling non-financial misconduct (NFM) in financial services are (finally) here. On 2 July 2025, the FCA published its final rules in Consultation Paper...more
On June 11, 2025, FINRA proposed amendments to Rule 3220 (Influencing or Rewarding Employees of Others) (the “Gifts Rule”) that would raise the annual gift limit per recipient to $250 from $100, as well as codifying...more
On May 16, 2024, the SEC adopted amendments to Regulation S-P requiring broker-dealers, registered investment companies, registered investment advisers, funding portals, and transfer agents (collectively, “covered...more
In December 2024, a task force consisting of 24 representatives from the Democratic and Republican parties issued a 273-page report with key findings and recommendations in relation to Artificial Intelligence on a...more
The Digital Operational Resilience Act (DORA) establishes a harmonised and comprehensive framework for information and communication technology (ICT) risk management in the financial sector. It is a directly applicable EU...more
Make no mistake, nonfinancial misconduct remains at the top of the Financial Conduct Authority's agenda. Originally published in Law360 - November 26, 2024....more
The Consumer Financial Protection Bureau has long required that an institution within the scope of its supervision or enforcement authority, including both depository institutions like banks and non-depository consumer...more
Conducting an independent AML audit at a frequency based on the nature, scale and complexity of the entity is a requirement under the AML Regulations. AML audits are an important component of the control environment to...more
The Digital Operational Resilience Act EU 2022/2554 (DORA) constitutes a groundbreaking EU regulation designed to establish a unified framework for bolstering cybersecurity and operational resilience within the financial...more
The SEC recently took action against Gainvest Legal Corp. and its owner. This action serves as a stark reminder for others in the financial services industry about the importance of a custom-tailored compliance program and...more
Every week, the Array team reviews the latest news and analysis about the evolving field of eDiscovery to bring you the topics and trends you need to know. This week’s post covers the week of July 8-14. Here’s what’s...more
Essential Guidelines for Ensuring Your Organization is Ready for January 2025. We are more than halfway through the year and the urgency to achieve DORA compliance by the fast-approaching January deadline is becoming...more
As artificial intelligence (AI) continues to advance rapidly, organizations of all types are seeking to deploy this powerful tool to increase the effectiveness and efficiency of their operations, improve service to their...more
On April 17th, the SEC issued a Risk Alert titled “Initial Observations Regarding Advisers Act Marketing Rule Compliance.” Perusing the list of failures, a sense of familiarity arose, given that one of our clients had been...more
On April 17, 2024, the Division of Examinations (the “Division”) of the Securities and Exchange Commission (the “SEC”) published a Risk Alert entitled: “Initial Observations Regarding Advisers Act Marketing Rule Compliance”...more
What is a Management Body? Under both DORA and NIS2, a management body can be a body with managerial and/or supervisory functions. The powers and structure of management bodies vary within the EU Member State, and managerial...more
A lengthy decision recently issued by the U.S. District Court for the Eastern District of Pennsylvania, Pennsylvania by Shapiro v. Mariner Fin., LLC, No. CV 22-3253, 2024 WL 169654 (E.D. Pa. Jan. 12, 2024) (Hodge, J.), may...more
On November 1, 2023, New York Department of Financial Services (NYDFS or the “Department”) released the finalized revisions (the “Second Amendment”) to 23 NYCRR Part 500 (Part 500) – the most significant modifications to Part...more
The Fortieth Cambridge International Symposium on Economic Crime, held recently, was entirely focused on “Integrity”. This highlights the importance of integrity in organisational life (as well as in our private lives)....more
On November 1, 2023, the New York Department of Financial Services (NY DFS) published its highly anticipated final amendments to its influential cybersecurity requirements for financial services companies (Part 500)....more
If you’re offering a financial product or service to consumers, such as a deposit account, loan, credit card, or payment service, you need a strong consumer complaint response function. This is true whether you’re an...more
Hosted by American Conference Institute, the Mexico Summit on Anti-Corruption & Compliance Programs returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance...more
On June 16, the CFPB issued an interpretive rule reversing its prior determination that it lacked authority to examine institutions for compliance with the Military Lending Act (MLA). In 2018, the CFPB discontinued checking...more
Nothing is scarier than 2020! But Bradley has you covered with a treat. Here are a list of “Things That Go Bump in the Night: Top 10 Considerations to Watch Out for in the Small Dollar Lending Industry.” Wishing you a...more
For financial services firms understanding who the Ultimate Beneficial Owner (UBO) of a corporation is has become a central compliance task. As Ellen Lafferty explains in this podcast and in the new edition of The Complete...more