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Innovate or Incriminate: Safeguarding Financial Institutions from Money Laundering Risks

December 4, 2023 | Due Diligence Financial Crime Consulting Risk + Compliance

What You Need to Know

In October 2023, the Department of Treasury’s Office of Foreign Asset Control (OFAC) enacted multiple sanctions targeting the supply chain of fentanyl and other illicit drugs. In addition to sanctions compliance obligations, financial institutions that deal in trade finance should modify their existing sanctions and suspicious monitoring programs to identify narcotics traffickers who produce, sell and purchase chemicals of interest. These additional efforts would both combat the fentanyl crisis and limit the financial institution’s risk … Read More

How Houses of Worship Can Best Prepare for The Worst

November 7, 2023 | Institutional Integrity National Security Risk + Compliance

Since my initial post on this subject in 2018, the world has once more undergone significant shifts, both on the global stage and within our own borders. As a result, I have taken a few moments to revisit my thoughts on this topic.

With the ongoing conflicts in the Middle East and the seemingly persistent gun violence in our own country, heightened concerns around the security of diverse faith communities have prompted us all to reevaluate and increase safety within … Read More

Summer Doldrums? Not for Human Resources Teams and I-9s!

July 26, 2023 | Immigration + Border Services Monitoring Risk + Compliance

I don’t think the word “doldrums” is used very much anymore, but I do remember it vividly from when I was a child. It was predominantly used in connection to the lazy hazy days of summer when things were hotter than heck and humidity was always higher than anyone wanted. When schools always started back up after Labor Day, August was considered the summer doldrums, especially when you knew it was inevitable that vacation time was soon coming to an … Read More

Lines of Authority: The Critical Need for Role Clarity in Information Security Compliance

July 19, 2023 | Compliance Risk + Compliance

Clearly defined roles and responsibilities are an essential component of an effective compliance program. Failure to adequately assign responsibility can lead to gaps in compliance coverage and a lack of accountability.

In a recent NAVEX survey 76% of the respondents indicated that the compliance function in their infosec compliance group is not an independent Compliance department reporting to the chief executive officer or board of directors (for instance, it reports up through IT/data security/data privacy, Legal or Human Resources).

When … Read More

Compliance Experts Discuss Off-Channel Communications and Mobile Surveillance Policies

May 23, 2023 | Compliance Risk + Compliance

Roundtable Discussion: Off-Channel Communications and Mobile Surveillance Policies

Surveillance, monitoring, escalation, and reporting are critical components to regulatory compliance and risk management. So is consequence management. These are especially important given the major penalties and remedial steps required of banks and swap dealers, and in view of recent US Department of Justice (DOJ) expectations over “Off-Channel Communications”.

These regulatory and ethical expectations aren’t easy to execute, especially when employees have access to so many modes of video, audio, and social … Read More

Forget Spy Balloons – The Bigger Threat is TikTok

March 22, 2023 | Cyber Security Monitoring Privacy Risk + Compliance

After the downing of the Chinese spy balloon by U.S. Forces in early February 2023, several additional objects have been identified over U.S. and Canadian airspace. While officials have denied that these were additional spy balloons, many have questioned what information was collected by these aerial spy devices, and for what purposes. Even though this is significant to national security, most citizens aren’t personally worried about this breach of privacy.

We suggest that an even greater threat to the average … Read More

Focus on Foreign Banks’ Sanctions Compliance Programs in the U.S. and Globally
Upgrading and Empowering Compliance to Help Address National Security Risks 

January 10, 2023 | Financial Crime Consulting National Security Risk + Compliance

As the Russia – Ukraine war rages on, one outcome so far is clear:  the Western nations remain aligned and united to confront Russian aggression. The West’s synchronized, roll-out of economic and trade sanctions against Russia since February 2022 combined with their limited military support, demonstrate that the West’s tight, global coordination helps Ukraine courageously defend its nation and citizens. Importantly, coordinated alignment also protects the homeland and critical infrastructure of each Western nation, including that of the United States.… Read More

“Chipping” Away at the Right to Fundamental Research?

November 7, 2022 | Compliance National Security Risk + Compliance

New Export Control Regulations Must Be Examined to Ensure Protection of International Research Collaborations

U.S. government actions to enhance and protect U.S. technological innovation have been regularly featured in recent headlines. With the consistency of a drumbeat, press releases have announced new federal prosecutions, coordinated federal agency regulatory action, and bipartisan Congressional legislation designed to boost U.S. technology and protect it from malign foreign influences.

As a matter of fundamental U.S. policy, the federal government has made clear that promoting … Read More

Physical Security. Risk Mitigation. Where to Begin?

August 11, 2022 | Physical Security Risk + Compliance

Why are you operating your physical security program? What threats are you trying to protect against? What specific risks to your organization and enterprise are you trying to mitigate?

If you cannot quickly and succinctly answer these questions, you may have skipped the critical step to developing a foundation for your physical security program – conducting a Threat and Vulnerability Risk Assessment (TVRA). Basing your physical security program on the results of a formal TVRA process defines the reasoning and … Read More

Tax Benefits for Improving the C-Suite’s Security:
A Look at IRS Code 132 and Working Condition Fringes

August 2, 2022 | Risk + Compliance Security Consulting

What if I told you that a security assessment of your business and residence could provide tax deductible expenses for private air transportation, a security driver, and executive protection agents and have favorable tax treatment too? Do I have your attention yet? 

Many executives are unaware of the benefits offered by 26 CFR § 1.132-5(m) – Working condition fringes, as it relates to security. In order to qualify for these conditions, it all begins with an Independent Security Study or Read More