• Vexing vendors?

    On April 13, 2012, the Consumer Financial Protection Bureau (CFPB) issued Advisory Bulletin 2012-03, which addresses vendor management rules and processes that are required to be used by supervised non-banks (See 12 U.S.C. §§ 5514-16). The bulletin requires covered non-bank consumer finance companies to develop and implement policies for risk...

  • The Yates Memo: Friend or foe to compliance officers?

    Last month, newly appointed Deputy Attorney General (DAG) Sally Quillian Yates spoke at New York University (NYU) School of Law about the Department of Justice’s ongoing focus on individual prosecutions. A seasoned prosecutor with a number of high-profile white collar cases under her belt, DAG Yates reminded the room...

  • Avoiding the big surprise: Evaluating regulatory compliance prior to closing

    Evaluating regulatory compliance in the thick of a deal can be an art unto itself. Doing it well requires a critical look at the sophistication and risk maturity of the target company, as well as a deep dive into data demonstrating compliance with applicable regulatory standards.

  • Anti-corruption: Five ways to turn policies into practices

    You have developed a comprehensive set of anti-corruption policies and procedures, translated them into 25 languages and rolled them out to your employees and business partners. Now what? For most companies, anti-corruption compliance is well embedded among employees at headquarters. However, confidence in compliance drops when it comes to satellite...

  • Regulatory priority

    In many ways, 2014 was the Year of the Data Breach. That year saw cyber-events at the Home Depot, JPMorgan Chase and Sony Entertainment, and the trend followed into 2015, with healthcare providers and government agencies showing that they, too, are vulnerable to attack. All of the incumbent attention that...

  • The perils of mixing personal and professional email

    Businesses need clear-cut policies about separating private and company-related digital communications

  • Bringing cybersecurity under a protective umbrella (of privilege)

    Cybersecurity is rife with legal issues and legal liability risks for the enterprise. Those issues and risks are the subject of a vast and rapidly expanding literature.

  • How unclaimed property issues impact American states differently

    With the new Uniform Unclaimed Property Act coming out soon, what do companies need to know and what changes are in store?

  • Compliance issues that should keep directors up at night

    With increased data analytics and monitoring capabilities, the set of tools available to regulators to identify and monitor companies for compliance breaches has expanded to unprecedented levels. As compliance breaches are identified, increasingly regulators are asking, Where was the board? Where was the oversight?

  • Out of sight, out of mind: What don’t you know and when should you find out?

    When you are preparing to sell property — or your business — a variety of issues should be considered in advance to make for a smoother and more reasoned sale. The environmental condition of your real property, for example, and the status of your company’s compliance with environmental laws, should...

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