RESULTS FOR: Monitoring
Despite an industry uproar, the sky is NOT falling with the U.S. Department of Justice (“DoJ”) requirement that chief executive officers (“CEOs”) and chief compliance officers (“CCOs”) certify that their compliance programs are effective.
Instead, a warm productive sunlight will shine upon CCOs and companies. That’s because these CEO / CCO certifications – if done well with independent validation – will empower the CCO while holding the CEO, C-suite, and their business executives more accountable for their conduct and compliance.… Read More
The Department of Justice has come knocking and is investigating your company for let’s say –serious money laundering or sanction violations or for manufacturing a defective product that has caused injuries or deaths.
The press is bad, raising grave questions about the company’s culture. Emails released to the public show that employees are afraid to speak up for fear of retaliation, or worse, employees are hiding misconduct from the regulators.
It’s just a matter of time before your company settles … Read More
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
October 30, 2017 | Monitoring
The recent series of natural disasters has left a staggering toll of ruin and loss. The instinct of all involved, citizens, businesses and government, is to clear the debris, restore energy and communications, and rebuild and repair infrastructure and buildings as quickly as possible.
Indeed, the recovery work itself is a cathartic experience that expresses hope in a restored future and the determination to get there.
Regulators, like prosecutors, are increasingly turning to independent monitors as a means of moving non-compliant entities into compliance. It appears certain that the appointment of independent monitors to enforce compliance with cybersecurity regulations will become common. Several financial industry regulators are moving to establish cybersecurity standards with which financial institutions will have to comply just as they do with money laundering and other regulations.