Imagine a virtual meeting in which an employee’s avatar nods in agreement. A colleague interprets that gesture as support for a business decision. But software, not the employee, generated the…
Imagine a virtual meeting in which an employee’s avatar nods in agreement. A colleague interprets that gesture as support for a business decision. But software, not the employee, generated the…
For years, many corporate compliance professionals saw the Committee on Foreign Investment in the United States (CFIUS) as primarily a concern for mergers-and-acquisitions attorneys. When a foreign investor sought to…
Ed. Note: This month, on his podcast series Popcorn and Compliance, Tom Fox dives deep into the first five Frankenstein movies. Over October, Tom Fox will consider Frankenstein, The Bride…
A manufacturer, technology company, retailer, or energy business doesn’t need to operate a bank to recognize the management problems this series examines. A commercially important relationship presents unresolved concerns. A…
A payment-routing problem, a stale watchlist, an incorrectly prioritized alert, and an employee processing error may initially seem like separate operational incidents. OFAC’s Enforcement Release asks compliance leaders to examine…
An automated compliance system can operate exactly as configured and still fail to perform the function the organization needs. That distinction is central to FinCEN’s findings concerning Bank of America’s…
A compliance program is tested when someone identifies a risk that the business would prefer not to address. The question is not whether compliance can produce a memorandum. The question…
Ed. Note: This month, on his podcast series Popcorn and Compliance, Tom Fox dives deep into the first five Frankenstein movies. Over October, Tom Fox will consider Frankenstein, The Bride…
I don’t just enjoy movies for my annual October Movie Monster-fest. I have been reading Tom Mead’s Joseph Spector mysteries, and the puzzles have brought me back to a question…
Paying a penalty and demonstrating an effective compliance program are different tasks. The AMEX enforcement actions make that distinction concrete. In Part 1, we examined the OCC’s $350 million civil…
