The Latest on Sustainability and Due Diligence

December 06, 2018 corporate social responsibility, csr, supply chain

Corporate compliance professionals had two years to prepare their organizations for the arrival of the European Union’s General Data Protection Regulation earlier this year. Now enforcement of the GDPR is upon us — and early indicators are that GDPR compliance is a matter EU privacy regulators will take seriously. Compliance officers should do the same.

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An Update on GDPR Enforcement

September 20, 2018 FCPA, FCPA enforcement

Corporate compliance professionals had two years to prepare their organizations for the arrival of the European Union’s General Data Protection Regulation earlier this year. Now enforcement of the GDPR is upon us — and early indicators are that GDPR compliance is a matter EU privacy regulators will take seriously. Compliance officers should do the same.

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Compliance officers talk constantly about the importance of automation and data analytics, and for good reason: they are crucial to successful management of a modern compliance program. So what’s the relationship between those two forces and third-party automation technology? How should compliance officers plan their strategies for more automation and […]

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OECD’s New Guide on Due Diligence for Ethical Conduct

June 07, 2018 ABAC, Due Diligence, third-party compliance

Corporate compliance officers have another item for their bookshelf: the OECD’s Due Diligence Guidance for Responsible Business Conduct, published on May 31 after three years of consultation and work. The guidance itself is as useful as any other work in the field: available as a free download: 100 pages, and [...]

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The corporate compliance community was jolted this month by news that Michael Cohen, long-time legal counsel and fixer for President Donald Trump, received millions of dollars from corporations after the 2016 election, supposedly for consulting services on a wide range of matters. That money — at least $4.4 million — […]

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Panasonic Avionics Corp., a U.S. subsidiary of Panasonic that makes in-flight entertainment systems, settled charges with U.S. regulators on April 30 that it violated the Foreign Corrupt Practices Act for years in the 2000s. The case offers almost every lesson a compliance officer might want to discuss about anti-bribery programs. And Panasonic settled its charges with $280 million in penalties, a two-year deferred-prosecution agreement, and a compliance monitor. Clearly the lessons are worth learning.

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At the preliminary level, companies can rely on evidence supplied by the customer about beneficial owners and controllers. That is, the person opening the account can supply the documentation you need, and that can suffice provided that your firm “has no knowledge of facts that would reasonably call into question the reliability of such information.”

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Emerging technologies have a habit of sneaking up on corporate ethics and compliance functions, so anticipating their consequences is always a worthwhile pursuit. Today let’s turn our attention to one that already seems clichéd but is indeed an enormous issue: the Internet of Things.

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Boards give CCOs inadequate budgets; employees disregard training and policy manuals; business partners lie; audits fail to uncover misdeeds. Nobody likes those things, but they happen. The question for compliance officers is how to respond when those circumstances do happen. If anything, the high-profile cases seen more demonstrate how compliance officers should not respond to difficult circumstances.

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