Harry Cassin
Publisher and Editor
Andy Spalding
Senior Editor
Jessica Tillipman
Senior Editor
Bill Steinman
Senior Editor
Richard L. Cassin
Editor at Large
Elizabeth K. Spahn
Editor Emeritus
Cody Worthington
Contributing Editor
Julie DiMauro
Contributing Editor
Thomas Fox
Contributing Editor
Marc Alain Bohn
Contributing Editor
Bill Waite
Contributing Editor
Shruti J. Shah
Contributing Editor
Russell A. Stamets
Contributing Editor
Richard Bistrong
Contributing Editor
Eric Carlson
Contributing Editor
At a Financial Industry Regulatory Authority Conference last month, regulators reportedly stated that they consider companies liable for breaches notwithstanding the types of technical or security models followed, regardless of whether the regulatory model placed the responsibility on the company or not.… Continue Reading
Regulators are constantly telling compliance officers to take a “risk-based” approach to due diligence processes and procedures. In some cases, regulations go so far as to require third parties to be profiled appropriately based on their level of risk.… Continue Reading
Risk profiling third parties is now a critical stage of any due diligence process. As businesses continue to expand and grow, more and more factors must be considered when assessing the risk level of a given third party — whether a vendor, customer, or agent.… Continue Reading
Most companies looking for a third-party compliance solution now opt to have their data stored on cloud servers located in the jurisdictions where their employees are located and where their business operations take place.… Continue Reading
My undergraduate business law prof invited me to be a research assistant for her upcoming publication on honest services fraud. That was 2009 at the University of Miami. It was my introduction to compliance.… Continue Reading
Over the past several years, concepts that once served as basic elements to an appropriate customer due diligence program and that had simple definitions have morphed into requirements that are completely decentralized and that vary, based on factors such as geographical location, risk level, industry and business activity.… Continue Reading
It may not be intuitive for a compliance department to dig into the completeness, consistency and organization of a company’s employee and customer data. But the integrity of the data impacts almost every automated compliance solution a company implements.… Continue Reading
The European Commission issued a statement last week announcing more robust rules on the criminalization of money laundering and penalties for offenses.
The new rules were proposed by the Juncker Commission in December 2016 and are intended to align money laundering offenses and sanctions throughout the EU, with a special emphasis on terrorism financing.… Continue Reading
The White House announced on May 8 that the United States would pull out of the Joint Comprehensive Plan of Action (JCPOA) and reinstate sanctions on Iran to address that country’s nuclear program.… Continue Reading
In less than two weeks the new General Data Protection Regulations (GDPR) will be in full force. Most companies subject to the GDPR have prioritized efforts to implement necessary internal safeguard measures, procedures and required contractual provisions.… Continue Reading
The pressure on companies to identify and verify ultimate beneficial ownership or UBO information is growing, with more legal requirements being imposed, first by FinCEN, and most recently by the UK, which particularly targeted the British Overseas Territories.… Continue Reading
In 2015 OFAC penalized the National Bank of Pakistan for apparent violations of U.S. sanctions programs resulting from a software failure. According to OFAC, the bank’s New York branch processed wire transfers after its sanction screening tool failed to detect the name of the account — LC Air company Kyrgyztransavia — as belonging to Kyrgyz Trans Avia, a blocked entity.… Continue Reading
