The DOJ’s April 2019 guidance for prosecutors on compliance programs reflects a belief that even as risk taking drives business behavior, so too should legal (particularly criminal) risk drive and inform a business’s compliance program. Simply stated, the more significant the risk-taking environment, the greater the chances for criminal behavior. The guidance recognizes that “each […]

COMPLIANCE = It’s all about making it easier to do the right thing and harder to do the wrong thing To help compliance and ethics practitioners to effectively perform their role, The Red Flag Group® has devised some suggestions for compliance officers to get ahead and demonstrate that they can add value in their companies. […]

It has been reported that STM has been fending off a probe led by officers from the Gibraltar police’s Money Laundering Unit who have arrested and released two employees, including chief executive Alan Kentish on suspicion of failure to disclose. Furthermore, STM has failed in its efforts to impose a news blackout on a crucial […]

There are many different options available to choose from when deciding how to record mobile phone calls. Which solution you choose to go with is dependent upon different factors including user requirements and budget. Here we list a few options for you to consider when deciding how to record mobile phone calls. In network recording […]

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has the power to punish compliance officers and other individuals for their company’s anti-money laundering control failures under the Bank Secrecy Act, a U.S. District Court in Minnesota ruled last week. The case involved a $1 million fine FinCEN imposed in December 2014 against the former chief […]

The key compliance challenge of the modern investment bank is to convince employees that their electronic communications are being monitored. The big bank fines and scandals of the post-crisis era are about stupid e-mails and electronic chats. The conduct was vague, ambiguous, hard to prove; the proof of nefarious intent came from all the dummies […]

It is amazing how often this notion still is dismissed out of hand.  To many, the thought is simply incredulous:  “Compliance is nothing more than a tick-the-box business:  do the minimum, stay out of trouble and focus on growing your business through all other means.” There is absolutely no benefit to a firm from doing […]

The Securities and Exchange Commission announced an award Wednesday of about $1.5 million to a compliance professional who provided information for an enforcement action against the whistleblower’s company. The award went to a compliance officer “who had a reasonable basis to believe that disclosure to the SEC was necessary to prevent imminent misconduct from causing […]