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Investment Firms, Beware Changing Compliance Goal Posts

October 15, 2018 | Compliance Financial Crime Consulting

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 Financial Crime Consulting

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
Read More

Regulators Are Catching Up With The Crypto Boom

October 4, 2018 | Compliance Financial Crime Consulting

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 Financial Crime Consulting

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

Sanctions Compliance Requires More Than a Filter

December 7, 2017 | Compliance National Security Risk + Compliance

As we detailed in our last post, sanctions compliance is becoming increasingly difficult because the amount of data companies ingest is increasing, and because both OFAC and prominent regulators such as the New York State Department of Financial Services and the Monetary Authority of Singapore (MAS) have clearly articulated that simply screening transactions is not sufficient.

The sanctions program that addresses the threat of North Korea, or the Democratic People’s Republic of Korea, effectively highlights the regulators’ expectations. … Read More

Sanctions in 2017: Where are we now

November 30, 2017 | Compliance National Security Risk + Compliance

As we approach the one-year anniversary of the Trump Administration, it is important to take stock of what has changed within OFAC regulations. This past year has seen several major changes to sanctions regulations, including the removal of most sanctions against Sudan (except for some list based programs), rollback of certain travel authorizations under the Cuban sanctions program, and a much-increased focus on North Korea and Venezuela.

In many respects, OFAC has not significantly changed their pace of designations, … Read More

DEA Registrants Play a Vital Role in Preventing Diversion

September 14, 2017 | Compliance

With roughly 64,000 people dying from drug overdoses last year and with nearly one-third of those deaths involving prescription painkillers, the current administration has declared the opioid epidemic a “National Emergency.” Every day more than 1,000 people are treated in emergency departments across the country for misusing prescription opioids. It is estimated that almost 80% of heroin users first struggled with prescription opioid addiction. In this sense, prescription painkillers are walking users to heroin’s door, across that threshold … Read More

Hiring Refugees in Response to Trump Executive Order?

February 2, 2017 | Compliance Immigration + Border Services

In response to the Trump Administration’s Executive Order temporarily banning refugees and certain immigrants with origins from seven specific countries, several U.S. companies publicly declared their commitment to the hiring of refugees.  Specifically, Starbucks pledged to hire 10,000 refugees over the next five years and LinkedIn signaled their intent to speed up the expansion of LinkedIn’s “Welcome Talent” refugee support program. Other companies are considering following the lead of Starbucks and pledging to hire existing and newly arriving refugees.

For … Read More