Insights

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

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

June 30, 2022 | Compliance Monitoring Risk + Compliance

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

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

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

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

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

March 23, 2021 | Financial Crime Consulting Risk + Compliance

Recently, 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

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

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