OFAC Issues a Framework for Compliance Commitments

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is published A Framework for OFAC Compliance Commitments. OFAC wants to provide organizations its perspective on the essential components of a sanctions compliance program. “As the United States continues to enhance our sanctions programs, ensuring that the private sector implements strong and effective compliance … Read more »

Compliance Bricks and Mortar for May 10

These are some of the compliance-related stories that recently caught my attention. Who to Sue When a Robot Loses Your FortuneBy Thomas Beardsworth and Nishant KumarBloomberg Business The timeline leading up to the legal battle was drawn from filings to the commercial court in London where the trial is scheduled to begin next April. It all started over lunch at a … Read more »

DOJ’s New Evaluation of Corporate Compliance Programs

The Justice Department released a refreshed set of guidelines on how prosecutors should evaluate corporate compliance programs. The Principles of Federal Prosecution of Business Organizations in the United States Attorney’s Manual describe factors that prosecutors should consider in conducting an investigation of a corporate entity, determining whether to bring charges, and negotiating plea or other … Read more »

Regulation S-P – Privacy Notices and Safeguard Policies

The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert on compliance issues related to privacy regulations. The alert comes from recent examinations of broker-dealers and registered investment advisers. Regulation S-P is the primary SEC rule regarding privacy notices and safeguards. The Risk Alert doesn’t cover all of the … Read more »

Howey Test – Framework for “Investment Contract” Analysis of Digital Assets

To show the markets that the Securities and Exchange Commission is not just about slapping around wrong-doers, but also trying to help people navigate the securities laws, the SEC’s FinHub published a framework for analyzing whether a digital asset is a security. The framework is not intended to be an exhaustive overview of the law; rather, … Read more »

Compliance Bricks and Mortar for April 5

These are some of the compliance-related stories that recently caught my attention. Companies Need to Pay More Attention to Everyday Unethical Behaviorby Yuval FeldmanHarvard Business Review Numerous studies have documented the prevalence of practices such as stealing office supplies, inflating business expenditures reports, and engaging in behaviors that raise conflicts of interest. While these may sound … Read more »