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 […]

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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

On April 30, 2019, the Criminal Division of the US Department of Justice released updated guidance on its Evaluation of Corporate Compliance Programs (“the 2019 Guidance”), replacing prior guidance released in February 2017 (“the 2017 Guidance”). Steele remains committed to keeping its clients, potential clients, and the broader corporate compliance […]

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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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Compliance Perspectives Podcast

January 23, 2019 Artificial Intelligence, machine learning

Christian Focacci, Vice President, Offering Management at Steele Compliance Solutions, sat down and demystified AI for compliance professionals.

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UK Sends Message on CEOs and Compliance

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.

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The Latest on Sustainability and Due Diligence

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

Earlier last month the world had a glimpse into how well large companies are implementing ideals of environmental care and fair labor into their supply chains and their own operations — and alas, the results were not great.

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