June 06, 2019 aml, guidance, ofac
May 20, 2019 aml, guidance, ofac
In what appears to be a flurry of updates and newly-issued regulatory guidance (see Steele’s coverage of OFAC guidance and DOJ’s Evaluation of Corporate Compliance Programs), the Financial Industry Regulatory Authority (“FINRA”) has just issued Regulatory Notice 19-18 (the “Notice”) to provide guidance to member firms regarding suspicious activity monitoring and reporting obligations under FINRA Rule 3310 (Anti-Money Laundering Compliance Program).
May 15, 2019 guidance, ofac, sanctions
The government agency charged with crafting the country’s sanctions programs has issued a rare and powerful piece of guidance. It is a detailed, prescriptive framework laying out what it considers a strong compliance program to prevent companies from breaching sanction rules – a missive that could mitigate or negate a penalty, or, in its absence, elevate the endgame to egregious.
May 02, 2019 ABAC, compliance, DOJ, policy
April 25, 2019 ABAC, compliance, DOJ, policy
March 26, 2019 ABAC, anti-corruption, Italy
The drumbeat of stronger, newer anti-corruption statutes continues across the world, and now Italy has joined the march with an overhaul of its anti-corruption law. Compliance officers with operations in Italy should take note and ensure that their compliance programs will keep pace with what the new law requires.
February 21, 2019 AI, compliance trends, GDPR
January 24, 2019 Due Diligence, software
January 23, 2019 Artificial Intelligence, machine learning
December 28, 2018 anti-money laundering, compliance
If corporate compliance officers need another example to show senior executives why a strong compliance function is so important, the U.K. Financial Conduct Authority has provided one — a monetary fine recently imposed upon a bank CEO personally, for his failure to nurture a strong anti-money laundering compliance program.