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Sanctions and The Supply Chain: Basic Steps to Protect Yourself

April 10, 2022 | Compliance National Security Risk + Compliance

With the Russian-Ukraine war’s ever-expanding sanctions landscape, the supply chain is even more complex than it already was, and enforcement risk is even higher given the broader array of U.S. federal and international agencies’ intent on strict compliance. It is increasingly necessary to regularly evaluate supply chain and trade operations to ensure companies are meeting their compliance expectations.  

For one, sanctions compliance is more than payments filtering and screening. It is also about export controls and licensing, cryptocurrency, and other Read More

The Joint Commission Has Added New Workplace Violence Prevention Requirements for the Healthcare Industry

April 7, 2022 | Compliance Design + Engineering Risk + Compliance Security Consulting

According to The Joint Commission (TJC), which oversees accreditation of hospitals and other healthcare facilities, about 73% of nonfatal workplace injuries and illnesses leading to missed work days in healthcare are connected to workplace violence. This figure does not consider the number of unreported incidents, so the actual percentage is likely higher.

Effective January 1, 2022, TJC introduced revisions to workplace violence standards that provide guidance for developing strong workplace violence prevention systems.

As a participant in ASIS International’s publication … Read More

Association of American Universities Adopts Principles to Address Sexual Misconduct and Retaliation on University Campuses

November 16, 2021 | Institutional Integrity Risk + Compliance

The presidents and chancellors of the Association of American Universities (“AAU”), an organization composed of 66 research universities across the U.S., announced on October 26, 2021, that it adopted eight new principles to address sexual misconduct in all forms, including sexual and gender-based harassment and related retaliation.

In a strongly worded statement, the AAU and its member institutions declared that they are unanimously “dedicated to supporting an environment in which students, staff, and faculty can fully participate in the campus … Read More

Grassley Leads Bipartisan Group in Effort to Bolster False Claims Act

September 13, 2021 | Compliance Risk + Compliance

The pandemic hit, mayhem and lockdowns ensued, and trillions of dollars were appropriated for COVID relief by Congress. It’s a lot, and as response and recovery continues to unfold, fraudsters saw an opportunity and are taking it. In response, Senator Chuck Grassley (R-IA) – historically a champion of the False Claims Act (“FCA”) – is leading a bipartisan group of senators who have proposed legislation, the False Claims Act Amendments Act of 2021 (“FCA Amendments Act of 2021”), that, if … Read More

5 Tips to Best Position Your Fintech for a Banking Charter License Application

March 23, 2021 | Financial Crime Consulting Risk + Compliance

5 tips for fintechs applying for a banking charter licenseRecently, several financial technology (“Fintech”) organizations have applied for – and been granted – banking charter licenses. For example, in May 2019, Grasshopper was approved for a charter issued by the Office of the Comptroller of the Currency, while in July 2020, Varo Money was approved for a national bank charter.

As mentioned in an earlier post, in March, Square, Inc. (“Square”) announced that it had commenced banking operations under its independently governed subsidiary industrial bank, Square Financial Services … Read More

The Unique Advantages Fintechs Have When Expanding into Banking Operations – A Trend is Underway

March 12, 2021 | Financial Crime Consulting Risk + Compliance

In 2021, Square, Inc. (“Square”) announced that it had commenced banking operations under its independently governed subsidiary industrial bank, Square Financial Services (“Square Financial”). The announcement comes after Square successfully completed the charter approval process with the Federal Deposit Insurance Corporation (“FDIC”) and the Utah Department of Financial Institutions for an Industrial Bank/Industrial Loan Corporation (“ILC”) license. Square Financial will offer business loan and deposit products, beginning with underwriting and originating business loans for Square’s existing sellers who use its … Read More

Hostile Takeovers – It’s Time to Dust Off the Defensive Playbook

February 22, 2021 | Due Diligence Risk + Compliance

Hall of Fame Pitcher Satchel Paige once said, “Don’t look back. Something might be gaining on you.” This great advice could use a revision:  look back, for what’s behind you may be catching up.

Hostile takeovers are back in the news. Recently, CoreLogic, the real estate industry data and analytics giant, had to beat back a takeover bid from Cannae Holdings and Senator Investment Group, eventually approving a merger agreement with two private equity firms, Stone Point Capital and Insight Read More

Not So Remote Insider Threats

February 10, 2021 | Due Diligence Risk + Compliance

6 tips to protect against insider threatsInsider threats, a security risk that comes from inside the organization itself, continue to be a risk for organizations even in the midst of a global pandemic.  With many employees working remotely and dealing with the challenges COVID-19 presents, it is easier than ever for employees to be recruited even unintentionally by threat actors. That’s because adversaries now have access to free or commercially available technological tools. These tools, which include forms of social media, encrypted communication platforms, and dedicated … Read More

The Ransomware Payment Risk

January 27, 2021 | Cyber Security Risk + Compliance

Deciding whether or not to pay off a criminal that has crippled your organization’s operations with ransomware is a painful undertaking.  It is a crucial decision that must be made at a time often described as “pure chaos.” Management, attorneys, IT staff, incident response/digital forensics experts, the communications team, insurance companies and others all take part in addressing the crisis with an eye toward restoring operations to normal as quickly as possible.  Time is of the essence.  When technical recovery … Read More

The SEC (Sort of) Weighs In on How Personal Liability for Chief Compliance Officers May Undercut Effective Compliance Programs

December 14, 2020 | Compliance Risk + Compliance

Although regulators often seek to empower compliance officers within their institutions, a troubling question lingers as to whether regulators are undercutting this important message by simultaneously sending mixed or unrefined signals about when a Chief Compliance Officer should be held personally liable for the compliance failings of his or her firm. The director of the U.S. Securities and Exchange Commission’s Office of Compliance Inspections and Examinations recently urged investment firms to empower Chief Compliance Officers (CCOs), saying, “The CCO is … Read More