Category Archives: Regulation

Extraterritorial Anti-bribery and Anti-corruption Compliance Requirements – A Third Party Perspective

In Pharmaceutical Compliance Monitor, William Marquardt discusses expectations to comply with extraterritorial anti-bribery and anti-corruption (AB/AC) regulations, and costs associated with these expectations.

Mitigating the Peril of the Chief Compliance Officer

By: David A. Holley

In December, I wrote here about the New York State Department of Financial Services’ (DFS) proposed regulation, Part 504 of the DFS Superintendent’s Regulations, to bolster regulated financial institutions’ abilities to combat terror financing and money laundering. The proposed rule provides, among other things, minimum guidelines for institutions’ transaction monitoring and sanctions interdiction programs. In addition, the regulation has a Sarbanes-Oxley–like component requiring the chief compliance officer (CCO) or functional equivalent to submit a yearly certification attesting that the firm is compliant with the new regulation.

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CSR Programs and Charitable Donations: FCPA Compliance Challenges

By William Marquardt

Introduction

Companies in the mining and energy sectors often operate in remote locations and find themselves working with indigenous communities who have no official say in the company’s operations, and yet are often dependent on these businesses to provide critical public services. In some jurisdictions these services are part of the concession or a statutory requirement of being allowed to operate in the locality, while others have no formal structure. Continue reading CSR Programs and Charitable Donations: FCPA Compliance Challenges

New York State’s New Regulation to Stem Terror Financing

By David Holley

In the last few years, the New York State Department of Financial Services (“NYSDFS”) has fined financial institutions billions of dollars for lapses in their terrorist financing, sanctions, and anti-money laundering compliance programs. In recent enforcement actions, the NYSDFS has not only levied fines, but also sought to hold individuals involved in intentional circumvention of these laws accountable by seeking their termination or banning them from working in New York State–licensed entities.

Continue reading New York State’s New Regulation to Stem Terror Financing