Compliance Communications Blog

 

"FinCEN's Advisory Aims at Culture"


10/15/14:
The Financial Crimes Enforcement Network (FinCEN) is not amused by recent enforcement actions against financial institutions. According to a post by Michael Volkov on 
Corruption, Crime & Compliance,  FinCEN’s frustration is based on what the agency believes are the “paper compliance programs” used by many financial institutions...

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"What Does Ethics Have to Do with It"


8/1/14:
Today’s businesses stand on an undercurrent of suspicion by many consumers and competitors that unethical behavior is an integral part of business success. Ugly assumption – and one not based in truth according to Jeff Kaplan, editor of the Conflict of Interest blog. In this post, Kaplan pulls up research to suggest that ethics...

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"Is a 'Little' Bribe Really a Bribe?"


8/1/14:
Facilitation payments continue to bedevil compliance officers, and for good reason. Tom Fox frames a post about facilitation payments by recognizing that they represent one of the most confusing elements of the FCPA. But, he notes, “Facilitation payments are small bribes but make no mistake about it, they are bribes.” So, how...

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A 'Culture of Compliance' According to FinCEN


8/1/14:
A post by Julie DiMauro on the FCPA Blog provides a brief overview of the recent advisory from the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) on a “culture of compliance.” Aimed directly at leaders of financial institutions under FinCEN’s jurisdiction, the advisory notes the responsibility of those...

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