Breaking the Mould

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Zahn Alimbay

WSJ Chief Compliance Officer Council Summit: Key Takeaways (Part I)

This week, I attended the inaugural The Wall Street Journal Chief Compliance Officer Council summit in London. We discussed the latest trends in ABC, geopolitical risks and sanctions enforcement, cybersecurity and AI regulations, industry best practices in training and third-party management, and the evolving role of the CCO. These are

The first comprehensive AI Act is here. It’s time to prepare.

Last month, the EU Parliament approved the world’s first comprehensive set of rules regulating the application of Artificial Intelligence. While the Act still requires endorsement from the European Council, it is a major development—the world’s first set of rules to govern AI. What do we need to

What can we learn from Ericsson?

On March 28, Ericsson announced that the independent compliance Monitor appointed by the US DOJ approved its Anti-corruption program and confirmed it is functioning effectively. [i]This opens the door to ending the four-year company’s monitorship. As a repeat corporate offender, Ericsson needed to do much to reach this

Enforcement trends 2024

Following the “quieter” 2023, enforcement agencies are scaling up their activities. What do their actions tell us about the direction? Let’s focus on three areas dominating the enforcement agenda: bribery, sanctions, and record-keeping violations (off-channel communication) in the financial sector. Broadening the pipeline Historically, in case of repeated violations,

How effective is your Compliance program?

How effective is your Compliance Program? Does it work in practice? Does it produce the intended outcomes? These are questions worth asking. But first, how can you even measure compliance effectiveness? You are in the right place – this is at the heart of everything we do in Comhla, and we

Tone from the Top

Many organisations have articulated values and ethical standards to which they adhere. But without a clear Tone from the Top, those values and standards are just declarations. Often, leaders underestimate the effect their actions have on the organisation and its employees. Employees are more likely to adhere to the organisational

How good is your sanctions compliance program?

On the 2nd anniversary of Russian aggression against Ukraine, the US, UK, EU and other countries have passed a new round of sanctions, including sanctioning more than 850 targets in Russia and around the world. Failure to implement a robust sanctions compliance program can open organisations to significant financial, regulatory

Third-party management matters. A lot.

The new Economic Crime and Corporate Transparency Act 2023 has put an added focus on the potential exposure originating from third-party relationships. Larger organisations can now be liable for fraud committed by associated persons. This is not new. Over the years, US enforcement agencies have held organisations accountable for failure

Integrity Ambassador Network is an invaluable asset worth having.

The first step in instilling a culture of integrity in an organisation is to ensure employees know what your organisation stands for, are aware of the expectations, are guided and supported on their journey, and, importantly, feel they are listened to and heard. But what do you do if your

UK’s Economic Crime and Corporate Transparency Act 2023 is here. Now what?

On October 26, 2023, ECCTA 2023 has received a Royal Assent. Heralded as bringing a sweeping reform to the UK economic criminal laws, the new Act aims to both close decades-long loopholes as well as to expand the UK’s corporate liability for economic crimes. The new law makes it