Sapin II in Practice: Our First Look

August 06, 2019 ABAC, AFA, Sapin II

What are the key failures and program trends OFAC has highlighted in major enforcement actions against financial institutions and corporations?

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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).

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OFAC Issues New Framework for Sanctions Compliance

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. 

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Evaluation of Corporate Compliance Programs

May 02, 2019 ABAC, compliance, DOJ, policy

Steele remains committed to keeping its clients, potential clients, and the broader corporate compliance community up-to-date on events such as this. Steele offers the following commentary and insight into the newly issued 2019 Guidance.

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DOJ Policy Change for Business Comms. Via Messaging Apps

April 25, 2019 ABAC, compliance, DOJ, policy

Compliance officers should carefully consider a change in FCPA enforcement policy from the Justice Department that gives companies more discretion in how employees can handle business communications — discretion that, in practice, may be more trouble than it’s worth.

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Italy Implements New Anti-Corruption Law

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.

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Preparing Compliance Functions for 2019

February 21, 2019 AI, compliance trends, GDPR

So what can we predict about compliance trends in 2019? Even just a few months into the year, compliance professionals can already see some issues that will command a higher profile in the months to come.

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Lessons in Misfired Due Diligence Software

January 24, 2019 Due Diligence, software

Compliance professionals might want to take note of a small but telling sanction that the Treasury Department recently imposed on a Virginia company — a case filled with important lessons about third-party due diligence and how to fulfill that task properly.

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