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The Evolution of #MeToo – A Call to Bravery

March 26, 2019 | Compliance

How to Communicate Your Commitment to a Harassment Free Workplace

It’s been more than a year since I first wrote about the emerging #MeToo movement and its impact on employers. A lot has changed since then. While I knew more would come to light regarding the harassment of women in the workplace, I am surprised at the breadth and scope of what the #Me Too movement has exposed. Every day, we hear more examples of extreme sexual misconduct and sometimes

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Tech Alone Is Not Enough To Fight Financial Crime. Here’s Why.

February 14, 2019 | Compliance

As published in Forbes, February 7, 2019.

Financial crimes, and the people who commit them, continue to evolve with the digital age. Traditional methods for combatting these crimes can no longer be expected to work. Innovative, technology-based solutions to fight financial crime are now almost just “table stakes.”

As with most tech innovation, implementation is the key. And when it comes to tech solutions that combat financial crime, and therefore doing what’s necessary to become compliant, implementation isn’t easy … Read More

MWBE Contracting Fraud Conviction Signals Shift of the Enforcement Landscape and Alerts Companies to Reassess Compliance

January 3, 2019 | Compliance

“Those who scheme to defraud minority-owned businesses and their own employees must face the consequences of their actions. My office will continue to prosecute scam artists that try to take advantage of New Yorkers,” said New York State Attorney General Barbara Underwood in a press release.

Attorney General Underwood’s statement follows the December 7, 2018 conviction of Michael Martin, a former Albany, New York contractor, for defrauding minority-and women-owned business enterprises (MWBE), leaving a number of owners and … Read More

How Boards Should Tackle Sexual Harassment in the #MeToo Era

November 30, 2018 | Compliance

A previous version of this article was published in Corporate Compliance Insights on November 29, 2018 and written by Stephanie Douglas.

7 Steps to Minimize Risk

Today’s boards are increasingly aware of the significance and scrutiny given to their oversight obligations in the #MeToo era. Depending on the soundness and swiftness of their actions, an organization can be seen as capable and intent on “doing the right thing,” or it can appear to be slow to act or even unresponsive … Read More

Investment Firms, Beware Changing Compliance Goal Posts

October 15, 2018 | Compliance

Article originally published in Law360.com.

Private equity and hedge fund firms are under greater compliance scrutiny and, as a result, increased regulatory and legal exposure. The responsibilities of board members are not limited to investment performance monitoring. Regulators are now moving up the corporate ladder to identify wrongdoing. That means bringing actions against people who did not think they could be held accountable.

Understanding the risks of noncompliance extends far beyond the period when due diligence for an investment … Read More

The Digital Payment Crime Threat Portends A Fintech/Regtech Alliance

October 11, 2018 | Compliance

As published in PaymentSource.com, October 4, 2018.

 

Digital payments remain vulnerable to abuse by financial criminals seeking to make fast payments and undetected payments through the financial system.

 

There are multiple ways in which digital payments can be used by those laundering money, committing fraud, or financing terrorism. What are some of the risks fintechs should be thinking about, and what are the ways to mitigate them?

 

Because financial crime risks, properly mitigated, are in fact
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Regulators Are Catching Up With The Crypto Boom

October 4, 2018 | Compliance

As published in Forbes, September 27, 2018.

Say goodbye to the under-regulated era of cryptocurrency. While crypto trading on the more mainstream exchanges is fueling the market, it’s also bringing greater scrutiny from regulators, as shown by the recent report by the New York State Attorney General’s office (OAG) on crypto exchange abuse, The Financial Action Task Force (FATF) announcements about upcoming crypto standards, and warnings to investors. And as guidance emerges and enforcement actions increase, crypto exchanges will, … Read More

Out of Many, One? — The Future of U.S. FinTech Regulation

October 2, 2018 | Compliance

As published in FinTechWeekly August 29, 2018.

Not for the first time, the federal government and states are at odds over the future regulation of FinTech.

On July 31, 2018, the Office of the Comptroller of Currency (OCC) at the U.S. Department of the Treasury (DoT) announced it would begin accepting applications from FinTechs for special bank charters, which would allow them to operate nationally. But individual states and inter-state organizations are strongly opposed. The Conference of State Bank Supervisors … Read More

Should Your Company Seek ISO 37001 Certification to Strengthen Its Anti-Bribery Program?

February 14, 2018 | Compliance

In October 2016, the International Organization for Standardization (ISO) published ISO 37001, the first anti-bribery management system standard designed to help organizations prevent, detect and address bribery. ISO 37001 includes a series of measures and controls that represent global anti-bribery best practices. These measures and controls include the following and are designed to help an organization implement an anti-bribery management system from scratch or to enhance controls already in place:

  • Adopt an anti-bribery policy
  • Appoint a person to
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Before ICE Comes Knocking: Strategies to Address Worksite Enforcement

February 5, 2018 | Compliance Immigration + Border Services

If there was any doubt about whether the current Administration was going to add worksite enforcement back into ICE’s enforcement agenda, the answer is “YES”. On January 10, 2018, ICE Acting Director Tom Homan released ICE’s revised worksite enforcement strategy. The new strategy focuses on three identified prongs: compliance; enforcement; and outreach.

Specifically mentioned under the enforcement prong is “the arrest of unauthorized workers for violation of laws associated with working without authorization.” This is a significant change from … Read More