May 6, 2020 | Compliance
Various regulators have recognized in guidance, press releases, and the like, that financial institutions and other corporations may need to adjust some or all of their compliance operations to handle the challenges posed by the COVID-19 pandemic. Some guidance is easier to interpret and adhere to than others. Examination timing and logistics continue to be adjusted on a case by case basis and firms have been working directly with their primary regulators to make appropriate adjustments as needed. Some guidance … Read More
As we continue to work through the new world of COVID-19, it’s important not to lose sight of what is almost certainly on the horizon – post-COVID investigations. The federal government has poured trillions into not only containment and treatment, but also financial stimulus. In order to facilitate greater flexibility for healthcare providers attending to the onslaught of pandemic-related needs, the feds are waiving certain requirements. Nevertheless, healthcare facilities should be implementing careful compliance practices to help avoid potential claims … Read More
April 30, 2020 | Compliance
Today, U.S. Citizenship and Immigration Services issued an updated version of the M-274 I-9 Handbook for Employers. The updates follow the changes that resulted from the release of the revised I-9 Form on January 31, 2020. It also includes additional guidance for commonly asked questions and issues raised by employers.
The M-274 is the “go-to” manual for questions regarding I-9 completion and its continued updates are an extremely helpful way for the regulatory agencies to ensure that employers have … Read More
The New York State Department of Financial Services (NYDFS) has taken several high-profile enforcement steps in recent months against entities alleged to have taken advantage of doing business in New York State without the necessary regulatory license. Enforcement activity against the National Rifle Association (NRA), Athene Holding Ltd., as well as Trinity Healthshare and Aliera, serve as reminders that NYDFS takes very seriously the obligation to abide by New York statutory licensing requirements.
This is for good reason — businesses … Read More
The New York State Department of Financial Services yesterday issued an enforcement action against the Industrial Bank of Korea (“IBK”) for violations of New York’s anti-money laundering and recordkeeping obligations. It is the first of these type of BSA/AML enforcement actions issued by the Department in some time; this is not surprising, given that NYDFS, like other regulators, has been consumed with responding to the COVID-19 pandemic.
Significant elements of the Consent Order include:
Although perhaps not as brazen as the recent theft of a Van Gogh from a museum in the Netherlands, fine art can be an attractive target for accused money launderers like Nazem Said Ahmad. Mr. Ahmad was recently named a “designated person” by the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC). OFAC pointed to the use of a Beirut art gallery by Ahmad to launder money in support of Hizballah (a/k/a Hezbollah) just as it issued … Read More
Anyone who has been involved in U.S. government contracting knows that applicable rules and regulations have increased consistently over the years. Congress has used federal contracts to implement a wide range of policies, regulations, and laws, from labor laws to environmental concerns to subcontracting requirements to cybersecurity matters. This accumulation of federal regulations, along with state and local laws and regulations, creates a nest of complicated and often interdependent compliance-related obligations that the federal contractor must perform in connection with … Read More
February 27, 2020 | Compliance