Tag: DFS

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Everything Compliance

Everything Compliance – Episode 129, The Tribute to Navalny Edition

Welcome to the only roundtable podcast in compliance as we celebrate our second century of shows. In this episode, we have the quintet of Jonathan Armstrong, Jonathan Marks, Matt Kelly, Karen Woody, and Jay Rosen, all hosted by Tom Fox.

  1. Jonathan Armstrong talks about the most recent speech by the new SFO director. He rants about Julian Assange’s inane claims to be a journalist.
  2. Matt Kelly discusses the regulation of AI and looks at the new DFS regs around it. He shouts out to Alexei Navalny, who was murdered for his fight against corruption in Russia.
  3. Karen Woody takes a deep dive into the Panuwat trial and the concept of shadow insider trading. She rants about the senseless gun culture in America.
  4. Jonathan Marks discusses the state criminal charges in the FirstEnergy corruption scandal but then evolves into an epic rant, which he continues in Shout Outs and Rants about failures in corporate governance, internal controls, and gun violence in America. He really outdid himself this week.
  5. Jay Rosen looks at the dearth of DOJ-mandated monitorships and proposes a new concept, the self-monitorship. He shouts out the movie Love on the Spectrum and the Bill Bradley interview.
  6. Tom Fox shouts out to Ben Affleck for his DunKing Super Bowl commercial.

The members of the Everything Compliance are:

• Jay Rosen: Jay can be reached at Jay.r.rosen@gmail.com

• Karen Woody is one of the top academic experts on the SEC. Woody can be reached at kwoody@wlu.edu

• Matt Kelly, founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com

• Jonathan Armstrong is our UK colleague, who is an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at jonathan.armstrong@corderycompliance.com

• Jonathan Marks can be reached at jtmarks@gmail.com.

The host, producer, ranter (and sometimes panelist) of Everything Compliance is Tom Fox, the Voice of Compliance. He can be reached at tfox@tfoxlaw.com. Everything Compliance is a part of the Compliance Podcast Network.

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10 For 10

10 For 10: Top Compliance Stories For The Week Ending January 27, 2024

Welcome to 10 For 10, the podcast that brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance, brings to you, the compliance professional, the compliance stories you need to be aware of to end your busy week. Sit back, and in 10 minutes, hear about the stories every compliance professional should be aware of from the prior week. Every Saturday, 10 For 10 highlights the most important news, insights, and analysis for the compliance professional, all curated by the Voice of Compliance, Tom Fox. Get your weekly filling of compliance stories with 10 for 10, a podcast produced by the Compliance Podcast Network.

  1. God told Paster to commit cryptofraud.  (NYT)
  2. When fraud starts at the top. (FT)
  3. Shkreli lifetime pharma ban upheld. (Reuters)
  4. China is cracking down on data corruption. (South China Morning Post)
  5. Exxon sues to prevent shareholder climate petitions at Board meetings.  (BBC)
  6. Toughening China’s forced labor import ban is coming. (WSJ)
  7. Gen Z is taking on more part-time jobs. What are the compliance risks? (WaPo)
  8. Binance fights SEC oversight. (Reuters)
  9. The fraud of belts and roads.  (WSJ)
  10. ICBC was fined $32MM by DFS. (WSJ)

For more information on Ethico and a free White Paper on top compliance issues in 2024, click here.

You can check out the Daily Compliance News for four curated compliance and ethics-related stories each day, here.

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Daily Compliance News

Daily Compliance News: January 16, 2024 – The Crown Jewel Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen to the Daily Compliance News. All from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

In today’s edition of Daily Compliance News:

  • Crypto firm Genesis Trading was fined $8 million for compliance failures.  (WSJ)
  • Is the Chinese military as corrupt as the Russian army? (Business Insider)
  • Ackman threatens a law suit against Business Insider. (FT)
  • The Russian war reigned over Ukrainian oligarchs. (NYT)

For more information on Ethico and a free White Paper on top compliance issues in 2024, click here.

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2 Gurus Talk Compliance

2 Gurus Talk Compliance – Episode 15 – The I Don’t Like it Edition

What happens when two top compliance commentators get together? They talk compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s episode! In this episode, Tom and Kristy take on a wide variety of topics, including a visit to Florida Women.

The landscape of corporate compliance is ever-evolving, with recent developments posing new challenges and opportunities for businesses. Compliance is a dynamic process that requires constant monitoring and retrospective reviews to identify potential risks and changes. He also emphasizes the importance of involving compliance officers early in the due diligence process of mergers and acquisitions and acknowledges the complexities of managing conflicts of interest in networking and hiring. Tom and Kristy advocate for a proactive approach to compliance, highlighting the importance of regulatory resources such as the New York State Department of Financial Services’ cybersecurity rules. She also stresses the need for clarity and certainty in compliance practices, particularly in areas like mergers and acquisitions and conflicts of interest. Join Tom Fox and Kristy Grant-Hart as they delve deeper into these issues in the latest episode of the 2 Gurus Talk Compliance podcast.

 Highlights Include:

  1. Albemarle FCPA enforcement action. (FCPA Blog)
  2. DAG Monaco on more credit for self-disclosure, this time in M&A. (Radical Compliance)
  3. NYDFS Comments on proposed cyber disclosure amendments. (Compliance and Enforcement Blog)
  4. Michael Lewis and SBF. (The Dig)
  5. Identifying compliance blind spots. (CCI)
  6. Lawmakers Press NBA, Players Union on Forced Labor (WSJ)
  7. Can you tell the difference between acceptable networking and wrongful hiring practices? (FCPA Blog)
  8. Crypto Sector Seeks Lawyers, Compliance Officers After Reputational Hits (WSJ)
  9. Stop Obsessing About Work All the Time (WSJ)
  10. Two women stole bags of food from Florida Taco Bell during armed robbery, deputies say (Fox 25 Orlando)

Resources 

Kristy Grant-Hart on LinkedIn

Spark Consulting

Tom

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Daily Compliance News

April 7, 2023 – The Good Friday/Passover Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen to the Daily Compliance News. All from the Compliance Podcast Network. Each day we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Stories we are following in today’s edition of Daily Compliance News:

  • DFS shut Signature Bank for liquidity reasons, not crypto reasons. (WSJ)
  • When Elon yaps? (Reuters)
  • China has nothing to do with TikTok except defend it. (NYT)
  • Steinmetz blames George Soros for losing the appeal. (FT)
Categories
Compliance Into the Weeds

DFS Fines Coinbase

The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more. In this episode, Matt and I take a look at the recent NY state Department of Financial Services sanction involving the crypto trading platform Coinbase, which just agreed to pay $50 million to the DFS and to spend another $50 million over the next two years to improve its compliance program.

Some of the highlights include:

·      What was the fine and associated spending for?

·      What did the Coinbase compliance program fail on?

·      How did Coinbase’s explosive growth fuel a culture of non-compliance?

·      How did Coinbase fall further and further behind?

·      Why and how did the Coinbase solution worsen the problem?

·      Why does a company need to start with a solid foundation of clearly defined procedures?

·      What is the role of effective and efficient technology?

·      What are the lessons learned?

 Resources

Matt Kelly in Radical Compliance

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Daily Compliance News

December 17, 2022 – The Lavish Life Style Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you four compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee and listen to the Daily Compliance News. All from the Compliance Podcast Network.

Stories we are following in today’s edition of Daily Compliance News:

  • When does a lavish lifestyle = Red Flags? (NYT)
  • Amazon agrees to business practice changes in the EU. (NYT)
  • DFS issues guidance for banks on crypto. (WSJ)
  • Crypto has made corruption worse. (The Guardian)
Categories
Compliance Into the Weeds

DFS Fines Carnival Cruise Lines for Cyber Failures

Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In this episode, we deep dive into the recent New York Department of Financial Services enforcement action against Carnival Cruise Lines for failures in its cybersecurity reporting obligations.  Highlights include:

·      Why is Carnival Cruise Lines subject to the DFS?

·      What violations occurred?

·      Why were there false certifications?

·      What were the tactical cyber security violations?

·      Were they material?

·      Lessons for the compliance professional.

Resources

Matt in Radical Compliance

Categories
FCPA Compliance Report

Eric Young on the Fed and DFS Components of the Goldman Sachs Corruption Enforcement


In this episode, I am joined by Eric Young, recently retired long-time compliance professional. We explore an under-looked aspect of the Goldman Sachs FCPA enforcement action; the independent enforcement actions by the Federal Reserve Bank and state of New York’s Department of Financial Services.
Some of the highlights include:

  • Why was the Fed involved in the Goldman Sachs FCPA resolution?
  • The Fed Order seemed critical of Goldman Sachs compliance function. Do you find this criticism warranted?
  • Is the ongoing oversight of the Fed typical for this type of case?
  • Why was the state the New York DFS involved in the Goldman Sachs FCPA resolution?
  • What were the separate reporting obligations of the Goldman Sachs compliance function discussed in the DFS Order? Do such obligations exist at the federal level?
  • Were the dates, timing and amounts of these 3 bond offerings red flags?
  • Were the money laundering allegations in funding equally as troubling as the bribery and corruption? 

Resources
Federal Reserve Cease and Desist Order
State of New York, Department of Financial Services Consent Order

Categories
FCPA Compliance Report

Jordan Arnold and Surjeet Mahant on the DFS Cyber Enforcement Action on First American Title

In this episode, I take a deep dive into the first cyber-security enforcement action brought by the state of New York, Department of Financial Services. It was against First American Title. In this exploration I am joined by Jordan Arnold, the Chief Innovation Officer at K2 Intelligence FIN. He is the founder and Global Chair of K2 Intelligence’s Private Client Services practice, which provides privacy and security services to ultra and high net worth families and clients in the entertainment, music, and sports industries and Surjeet Mahant, Managing Director in K2 Intelligence FIN’s Financial Crimes Risk and Compliance practice, where he leads cyber risk services. With over 20 years of experience in cybersecurity and privacy risk solutions for large institutions, Surjeet assists clients in developing the tools and strategies needed to protect the confidentiality of their data, the availability of their systems, and the integrity of their operations.
Some of the highlights include:

  • Overview of the enforcement action;
  • What are the broader consequences for the industry; significance of regulation/action; need for proactive actions;
  • What is the DFS and why is it regulating an insurance company around cyber?
  • Why has cyber become a part of the broader compliance conversation?
  • What specific steps can entities take to mitigate a violation or breach of data?
  • What can entities expect in the future from regulators in the cyber space?

For more information on K2 Intelligence FIN, click here.