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RESULTS FOR: Compliance

DOJ Maintains Interest in Bribery in Mexico and Latin America

January 16, 2024 | Compliance Investigations Monitoring

Recent Department of Justice (“DOJ” or “Department”) activity on bribery in Mexico and Latin America sends a warning and provides a roadmap to companies doing business there.  By following the roadmap, companies may escape prosecution (or at least the imposition of a monitor) by enhancing their compliance programs.  While there is no guarantee that either prosecution or a monitor can be avoided, compliance program improvements are well worth the effort. First let’s review key takeaways from DOJ enforcement activity and … Read More

Immigration Alert: TPS Beneficiaries Re-Registration Period Extended

December 14, 2023 | Compliance Immigration + Border Services

On September 8, 2023, the Department of Homeland Security (DHS) announced it was extending the re-registration period for beneficiaries of Temporary Protected Status (TPS) under the designations of El Salvador, Haiti, Honduras, Nepal, Nicaragua, and Sudan.  Today, the Secretary of DHS published a Federal Register notice (FRN) to officially announce the extension from the normal 60-days to the full 18-month designation period of each country.

DHS cites many factors for the re-registration extension, including the pending TPS litigation, beneficiary confusion, … Read More

The SEC has new Cybersecurity Rules. Are you prepared and ready?

August 16, 2023 | Compliance Cyber Security

On July 26, 2023, the Securities and Exchange Commission (SEC) implemented new cybersecurity rules to require disclosure of material cybersecurity incidents within four business days, with limited exceptions.  Additionally, public companies will be required to provide annual disclosures regarding cybersecurity governance and risk management in order to be more transparent about their cybersecurity posture. These rules become effective in December 2023 and will influence both compliance costs and the potential for enforcement actions.

Companies and entities subject to these rules Read More

Lines of Authority: The Critical Need for Role Clarity in Information Security Compliance

July 19, 2023 | Compliance Risk + Compliance

Clearly defined roles and responsibilities are an essential component of an effective compliance program. Failure to adequately assign responsibility can lead to gaps in compliance coverage and a lack of accountability.

In a recent NAVEX survey 76% of the respondents indicated that the compliance function in their infosec compliance group is not an independent Compliance department reporting to the chief executive officer or board of directors (for instance, it reports up through IT/data security/data privacy, Legal or Human Resources).

When … Read More

Identifying Minors in High-Risk Jobs

June 28, 2023 | Compliance Immigration + Border Services Investigations

Recent investigative reports have revealed the Department of Labor’s crackdown on organizations found to have minors working in high-risk industries that prohibit employing anyone under 18 years of age. In a number of these cases, the minors were also identified as being unauthorized to work in the U.S. The convergence of these issues amplifies the potential for severe legal consequences, financial liabilities, damage to reputation, and operational disruptions.

Recently, Immigration and Customs Enforcement, Homeland Security Investigations, rebranded their “Worksite Enforcement … Read More

The EU and ESG: Why ESG matters to all multinational companies

June 26, 2023 | Compliance

Will US companies create their own business risk abroad by not adopting compliance policies for risks that they deem controversial or may not fully believe in at home? On the surface this may seem like a rhetorical question – one without a clear answer – but it has existential implications.

Better understanding of risks (known and unknown) was a key driver for my EU colleagues during the recent ASIS Europe 2023 held in Rotterdam, Netherlands. Given the recent events surrounding … Read More

Compliance Experts Discuss Off-Channel Communications and Mobile Surveillance Policies

May 23, 2023 | Compliance Risk + Compliance

Roundtable Discussion: Off-Channel Communications and Mobile Surveillance Policies

Surveillance, monitoring, escalation, and reporting are critical components to regulatory compliance and risk management. So is consequence management. These are especially important given the major penalties and remedial steps required of banks and swap dealers, and in view of recent US Department of Justice (DOJ) expectations over “Off-Channel Communications”.

These regulatory and ethical expectations aren’t easy to execute, especially when employees have access to so many modes of video, audio, and social … Read More

U.S. Attorneys’ Offices Voluntary Self-Disclosure Policy
Watch Out for The Next Logical Step – Enforcement

March 15, 2023 | Compliance

It is safe to assume that the United States Attorneys’ Offices Voluntary Self-Disclosure Policy announced on March 2, 2023 is intended to decrease wrongdoing and impose rehabilitation and recovery for victims.

But announcing voluntary disclosure is only half of the equation. The other half is vigorous law enforcement.

Simply put, companies must be made afraid of being caught.  This is the foundation for the successful voluntary disclosure policy of the Antitrust Division of the Department of Justice (DOJ).

But the … Read More

10 Key Elements of a Child Abuse Protection Policy

March 2, 2023 | Compliance Institutional Integrity

The care and protection of children at any public, private, religious, or secular organization or institution that supports children or vulnerable adults should be, one of, if not their highest priority. Accordingly, these organizations and institutions must ensure that their child abuse protection policies and procedures are comprehensive and current.  Here are 10 key elements to consider when determining whether your institution or organization is child abuse protection ready.

  1. Formal Written Policies: A written and comprehensive child abuse prevention policy
Read More

Mergers + Acquisitions: Mitigating Immigration Compliance Risk The Pros and Cons

January 24, 2023 | Compliance Immigration + Border Services

When companies intend to merge with or acquire another company, many risk factors must be evaluated prior to the transaction’s execution. However, immigration compliance risk is not always on the top of that list. And, that could be a potentially costly omission.

Immigration Compliance: Why It Matters:

Immigration compliance risk comes in two primary areas; 1) Work-related visa risk, and 2) I-9 compliance risk. While not all U.S.-based companies use work-related visas, they all must comply with the I-9 laws … Read More