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As Regulators Continue to Provide Guidance During These Unprecedented Times, Some is Easier to Interpret Than Others – A Focus on OFAC

May 6, 2020 | Compliance

Various regulators have recognized in guidance, press releases, and the like, that financial institutions and other corporations may need to adjust some or all of their compliance operations to handle the challenges posed by the COVID-19 pandemic.  Some guidance is easier to interpret and adhere to than others.  Examination timing and logistics continue to be adjusted on a case by case basis and firms have been working directly with their primary regulators to make appropriate adjustments as needed.  Some guidance … Read More

Post-COVID-19 Investigations and Healthcare Fraud

May 4, 2020 | Compliance Investigations

As we continue to work through the new world of COVID-19, it’s important not to lose sight of what is almost certainly on the horizon – post-COVID investigations. The federal government has poured trillions into not only containment and treatment, but also financial stimulus. In order to facilitate greater flexibility for healthcare providers attending to the onslaught of pandemic-related needs, the feds are waiving certain requirements. Nevertheless, healthcare facilities should be implementing careful compliance practices to help avoid potential claims … Read More

The CARES Act Auditors are Coming! Will you be Ready?

April 30, 2020 | Compliance

Under the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) and three other coronavirus related acts, Congress provided emergency relief to individuals and businesses adversely affected by COVID-19. With this legislation, Congress funded over $2 trillion in relief in lending programs, grants to businesses, and support for American workers.


Many of these loan and grant programs have specific limitations and restrictions on how loan proceeds and grant funding may be used. Some require participants to submit certifications and
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Prudent Generosity: Due Diligence of CARES Act and Other Covid-19 Emergency Loans

April 28, 2020 | Investigations

This week the White House and Congress agreed on a $484 billion funding deal to help small businesses, hospitals and Covid-19 testing. The spending package’s passage infuses another $310 billion into the Paycheck Protection Program (“PPP”), $60 billion of which was set aside for regional banks, community-based lenders and credit unions with an added $10 billion to cover lenders’ administrative costs. There’s also $60 billion allocated in the legislation for the Economic Injury Disaster Loans Program, which covers grants for … Read More

COVID-19 and Your Pending Workplace Investigations

April 27, 2020 | Investigations

COVID-19 and Your Pending Workplace Investigations

While our lives are changing in dramatic ways that tend to make us feel more isolated and insecure, the world of workplace investigations continues to move forward. Workplace investigations are built on a foundation of thorough effort that is conducted fairly and confidentially and is performed in a timely fashion. The novel coronavirus has the capacity to tilt the factors of timeliness and fairness on their axes.

COVID-19 dropped on the scene unannounced, and … Read More

Beware Scams Related to the Coronavirus

April 3, 2020 | Investigations

International fraudsters are already exploiting the Coronavirus and new federal CARES Act aid, relief, and stimulus programs, which include emergency cash payments to individuals and businesses. Expect the fraud attempts to continue throughout and after the pandemic.

Criminals are using various means to contact potential victims, including:

• spoofed (forged sender/header) email and phone calls posing as U.S. Treasury officials requesting potential victims provide personal identifying information (“PII”) to receive aid payments; and

• text messages with links to official-looking … Read More

Operational Impact of Coronavirus – Security’s Role in Protecting Against Business Disruption

February 10, 2020 | Security Consulting

After experiencing previous global health scares such Ebola, H1NI, SARS and MERS, pandemic response has become a standard emergency response procedure for most organizations. In 2011, when I was onboarding with a new company, we received detailed training on how to handle dead birds in the parking lot. This usually received a good laugh from the new employees; however, the company saw it as an important protocol, directly in response to the Avian Flu.

Emergency response plans typically include how … Read More