MyComplianceOffice Blog

Yes, that wonderful time of the year has arrived again. The time where most of your employees will receive gifts from customers and third-party. Risks are evident, but there are a few things to consider in order to maintain gift compliance. Read through the blog and ask yourself: Is your organization prepared to deal with corporate gifts this season and all year long? Are you aware of FINRA gifting guidelines?

The number of U.S. cases investigating Foreign Corrupt Practices Act (FCPA violations dropped in 2018. But there was considerable growth in FCPA enforcement actions, increasing by more than half the number of those issued just the year before. That’s according to a recent report from Trace International, Inc.  

The CEO of any financial firm will tell you regulatory compliance is one of their organization’s greatest challenges. The compliance part is easy. Regulators tell a firm what to do. Then they must do it or face often severe legal and financial penalties along with reputational damage. It’s HOW to create and implement effective compliance programs in efficient and affordable ways that presents issues for firms.  

The UK Bribery Act was implemented nearly eight years ago, but no case law exists to offer organizations an interpretation of corporate hospitality rules. The sole source of guidance to date has been from the Ministry of Justice in 2011.  

The U.S. Department of Justice (DOJ) relaxed its Foreign Corrupt Practices Act (FCPA) policy, better known as the “Yates Memo,” at the end of 2018. Previously, the DOJ required corporations provide all information on an employee’s potential misconduct to earn any cooperation credit during an investigation. The softened policy simply requires corporations identify individuals involved in potential misconduct to earn possible credit.