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DOJ’s Use of Data Analytics for Prosecutions Becomes the “Norm”

October 7, 2019 | Compliance

The Fraud Division of the U.S. Justice Department unsealed an indictment recently that charged three traders associated with a global U.S.-based bank with a racketeering conspiracy that involved alleged manipulation of the precious metals markets through “spoofing.” The indictment alleges numerous specific instances of spoofing, over an approximately eight-year period, intended to improperly affect prices for precious metals and related options. The U.S. Commodity Futures Trading Commission filed a parallel civil action against the three traders as well, likewise charging … Read More

The New Mandate of the Financial Action Task Force and Private Sector Engagement

May 6, 2019 | Compliance Financial Crime Consulting

On April 12, 2019, the government ministers and representatives of the Financial Action Task Force (“FATF”) agreed upon and issued a new mandate for the organization, the first revision since 2012. The new mandate represents a functional impact on the mission of the organization, as FATF ministers will soon commence meeting every two years, a FATF Presidency term will last for two years rather than one year, and the term of the FATF’s mandate is open-ended rather than requiring periodic
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Employer Alert – Interim State IDs Have Adverse I-9 Consequences

May 2, 2019 | Compliance Immigration + Border Services

Employers who have dedicated resources to developing a robust I-9 compliance program, and who also follow trends related to identification documents to prevent fraud, should pay attention to a new area of concern — interim driver’s licenses.

Many states have enhanced the security of their driver’s licenses and identification cards over the past several years. These enhancements consist of new security features, printing, holograms, and tamper resistant formats. Some states periodically enhance the security features of their documents, and others … Read More

Tell Me Some More Bad News: Encouraging The Internal Reporting Of Compliance Failures

April 29, 2019 | Compliance

As published in Forbes, April 22, 2019.

Last May, the U.K. Financial Conduct Authority and the Prudential Regulation Authority fined Barclays CEO Jes Staley over £600,000 for non-compliance with U.K. laws aimed at protecting whistleblowers. Then, in December, New York’s banking regulator fined Barclays another $15 million for its CEO’s wrongdoing. Mr. Staley had attempted to improperly identify a whistleblower employee who had written anonymous letters to the bank’s board and senior management raising concerns about a fellow employee. … Read More

The Cannabis Industry Moves Closer to SAFE Banking

April 26, 2019 | Compliance

The House Financial Services Committee recently voted in approval of legislation intended to increase the cannabis industry’s access to banking, and that’s huge. With a 45 to 15 vote that followed several days of debate and amendment considerations, the legislation advances to the full body of Congress.  While action on the floor has yet to be scheduled, this bill solidifies legalization advocates’ long-held hope that the House is prepared to take on sweeping marijuana reforms in 2019.

The House Financial … Read More

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 Financial Crime Consulting

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

How The DOJ’s New Guidelines on Monitorships Is an Opportunity for Corporations

October 23, 2018 | Monitoring

Navigating new criminal division guidance and accelerating remediation

As published in Corporate Compliance Insights on October 23, 2018.

In his remarks at the Corporate Compliance and Enforcement Conference last Friday, Assistant Attorney General Brian A. Benczkowski expanded on the Department of Justice’s (DOJ) new guidelines for corporate compliance and monitorships, issued on October 11, 2018.

While it is yet to be seen how these new guidelines will impact the frequency of monitorships, it does seem clear that the DOJ … Read More