Posted inBest Practices

Before the first crypto transaction, finance needs a seat at the compliance table

When an established company considers holding crypto, the compliance questions usually come first. Is the activity permissible? Is the exchange or custodian acceptable? Have the wallets been screened? Are AML and sanctions controls adequate? Those questions can all have satisfactory answers while the transaction still produces an outcome the institution did not intend. The reason […]

Posted inBest Practices

When compliance reporting creates false assurance

Boards are not short of compliance information. Most receive dashboards, heat maps, training figures, investigation data, audit findings, remediation updates, and regulatory summaries. The difficulty is deciding what all that information really says. A report can be accurate, well presented, and still leave directors with too much confidence. That happens when evidence of activity is […]

Posted inSanctions

How ordinary Russian investors got caught in the sanctions net

When sanctions against Russia began multiplying in 2022, the public images were hard to miss: Yachts seized in European ports, villas frozen, bank accounts linked to oligarchs blocked. What I remember from the compliance side looked less visible and much more procedural. It was passports, residence permits, source-of-wealth documents, ownership charts, explanations of old bank […]

Posted inBest Practices

Navigating the supply chainโ€™s new normal

A supply-chain disruption can look simple: A supplier cannot deliver, procurement finds an alternative, engineering qualifies it and production continues. Geopolitical disruption rarely arrives labeled as a compliance problem. It arrives as a sourcing decision, engineering fix or logistics reroute before compliance becomes involved. Recent developments include: Enforcement shows what can be at stake. In […]

Posted inBest Practices

Record-setting AML penalty against UBS was years in the making

FinCEN and several other regulators levied a combined $125 million penalty against UBS Financial Services (UBSFS), a broker-dealer and futures commission merchant, due to a series of long-standing compliance failures.ย The total penalty was a joint effort of federal regulators, including FINRA ($20 million), the Securities and Exchange Commission ($20 million), and the Commodity Futures Trading […]

Posted inBest Practices

Beyond breaching privacy: The compliance risks of workplace surveillance

When organizations implement workplace surveillance tools, the conversation often begins with privacy. Questions about employee consent, data collection, retention periods, and legal compliance are essential. But as workplace monitoring technologies become more sophisticated, focusing exclusively on privacy risks often overlooks a much larger challenge.

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