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
November 14, 2019 | Compliance
“The extension and expansion of New York’s nation-leading MWBE program will help ensure our economy is reflective of our values and of our diverse talent pool… and by signing this measure into law we will empower more women and people of color to participate in State contracts and continue our aggressive program to make contracting even more inclusive.”
October 31, 2019 | Compliance
As the state-legal cannabis industry continues to march forward at a nearly unprecedented pace, it has remained hobbled by federal legal constraints. The fact that cannabis is illegal at the federal level throws myriad wrenches into the works. Banking is the most notable sticking point.
To run a legitimate business, one needs access to a legitimate bank, but the federal government’s stance on cannabis makes banks hesitant to take on cannabis businesses as clients. In a response that many consider … Read More
October 28, 2019 | Compliance
Recent headlines highlight the arrests of officials from labor organizations or fringe benefit funds for spending union or health and welfare fund monies on vacations, luxury items, parties and pricey restaurants or for entering into collusive agreements with employers, extorting money, or criminally coercing concessions from vendors and suppliers. These actions violate the Hobbs Act. The consequences of such misconduct can be detrimental to say the least.
The cost of remedial litigation alone can be overwhelming, while the reputational … Read More
October 14, 2019 | Compliance
Whistleblowing is in the news. Current events are a timely reminder of the importance of having in place sound and up-to-date policies, procedures and programs for whistleblowing. A number of prudential regulators, such as federal and state bank regulators, and the Securities and Exchange Commission, all include review of a company’s whistleblowing program as standard in periodic examinations or inspections.
A robust whistleblowing program is an essential component of a comprehensive compliance program for financial institutions and other large corporations. … Read More
October 7, 2019 | Compliance
The Fraud Division of the U.S. Justice Department unsealed an indictment recently that charged three traders associated with a global U.S.-based bank with a racketeering conspiracy that involved alleged manipulation of the precious metals markets through “spoofing.” The indictment alleges numerous specific instances of spoofing, over an approximately eight-year period, intended to improperly affect prices for precious metals and related options. The U.S. Commodity Futures Trading Commission filed a parallel civil action against the three traders as well, likewise charging … Read More
Employers who have dedicated resources to developing a robust I-9 compliance program, and who also follow trends related to identification documents to prevent fraud, should pay attention to a new area of concern — interim driver’s licenses.
Many states have enhanced the security of their driver’s licenses and identification cards over the past several years. These enhancements consist of new security features, printing, holograms, and tamper resistant formats. Some states periodically enhance the security features of their documents, and others … Read More
April 29, 2019 | Compliance
Last May, the U.K. Financial Conduct Authority and the Prudential Regulation Authority fined Barclays CEO Jes Staley over £600,000 for non-compliance with U.K. laws aimed at protecting whistleblowers. Then, in December, New York’s banking regulator fined Barclays another $15 million for its CEO’s wrongdoing. Mr. Staley had attempted to improperly identify a whistleblower employee who had written anonymous letters to the bank’s board and senior management raising concerns about a fellow employee. … Read More