Best practices for high-performing compliance programs

It’s a tricky thing to understand what a high-performing compliance program actually looks like. Aside from activities and checklists and even anonymous tips, a high-performing compliance program must include the human element. Do we, as a company, believe we’re always doing the right thing? Because in the end, that is what compliance is all about.

We’ve been fortunate to work with and have at MCO some of the most respected leaders in the compliance space. And from them, we’ve crafted a few best practices for high-performing compliance programs that everyone can easily put into place.

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FCA Details Feedback on Final SMCR Consult

The Financial Conduct Authority (FCA) announced it has received just 29 responses to a call for feedback on its final consultation regarding planned Senior Managers and Certification Regime (SMCR) changes. The FCA said "most" responses were supportive of its proposals, but some firms asked for additional clarity on how the new rules would apply to them. 

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New Bill Seeks Clarity on Insider Trading Law

On May 7, 2019, U.S. Representative James Himes (D-Conn) introduced the “Insider Trading Prohibition Act,” which would amend the Securities Exchange Act of 1934, by inserting a new section that defines the elements of criminal insider trading. The bill was passed unanimously in the House Financial Services Committee on May 10. 

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Franchisors More Susceptible to Misconduct Violations

Franchisors are an example of a type of corporation more susceptible to misconduct risk than others, primarily because of their reliance on international distributors. Franchisors must therefore conduct rigorous internal compliance programs to ensure they are adhering to U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act requirements. Both regulations are international in reach and make it a crime to bribe a foreign official to secure an improper business advantage.  

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US Supreme Court Ruling should Spur Anti-corruption Efforts

The U.S. Supreme Court recently held protections in the International Organizations Immunities Act of 1945 against civil lawsuits in U.S. courts were not absolute. Instead, immunity granted to international organizations, including Multilateral Development Banks (MDBs), is no greater than that enjoyed by foreign governments under the Foreign Sovereign Immunities Act (FSIA).  

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