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AML Regulation and Compliance Trends

Corruption, Crime & Compliance Blog -

Regulators and enforcement agencies continue to pursue aggressive regulations and requirements for financial institutions (a very broad definition under Title 31 of the US Code and regulations).  The new administration does not show any signs of altering the course of agency priorities.  Money laundering, sanctions and securities enforcement has continued at a straight-forward pace from the Obama Administration.

The most significant upcoming development is FinCEN’s new Customer Due Diligence rule, which is effective in May 2018.  This new rule targets beneficial owner requirements and is long overdue since the United States is behind many other countries in requiring such disclosures.

FinCEN also has expanded its geographic targeting orders (GTOs) to additional jurisdictions to ensure that title companies report suspicious cash transactions to purchase real estate in high-risk cities and areas.  Eight cities (and additional New York City boroughs) are now on FinCEN’s GTO list. (Here is related FinCEN advisory on GTOs).

As to other priorities, Bank Secrecy Act and AML compliance has experienced increased focus on Suspicious Activity Report filing requirements.  The SEC and FINRA have devoted significant efforts to enforcing these requirements, especially against broker-dealers.  The banking agencies continued their focus on BSA and AML compliance and reviewing AML compliance program functions and elements.

Over the last few years, the New York Department of Financial Services has become a force to regulatory and enforcement force against national and global banks that maintain branches in New York.  The NYDFS requires certifications as to compliance with AML transaction monitoring and filtering programs.

Financial regulators also have converged compliance with cybersecurity and AML requirements.  The NYDFS issued in 2016 cybersecurity regulation requirements.  Meanwhile, on the federal side, banking regulators have mandated that compliance programs address AML and cybersecurity risks.  The SEC has pushed companies to enhance their cybersecurity disclosures as a further means to prod companies into addressing cybersecurity risks.  The BSA SARs filing requirements now incorporate cybersecurity issues as well.

De-risking is another hot topic in the AML regulatory arena which occurs when financial institutions withdraw from certain business lines or countries that the institutions find are too risky.  This particular concern arises when financial institutions operate foreign correspondent bank accounts.  In response to high compliance costs and regulatory scrutiny, banks have withdrawn from correspondent banking in high-risk countries.  Regulators have clarified certain requirements in this area – first, that there is no expectation that US banks conduct due diligence on the customers of the foreign financial institution and that AML and OFAC enforcement regime is not zero tolerance when it comes to customers of foreign financial institutions.

U.S. depository institutions are required to assess the money laundering risk presented by their foreign correspondent accounts by addressing: (1) the nature of the FFI’s business and the markets it serves; (2) the type, purpose, and anticipated activity of the account; (3) the nature and duration of the account relationship; (4) the supervisory regime of the jurisdiction in which the FFI is licensed; and (5) information about the FFI’s AML record.  Although there is currently no requirement for U.S. depository institutions to conduct due diligence on an FFI’s customers, banks should consider whether the due diligence information provided by their FFI customers is sufficient to fully assess the AML and sanctions risks posed by the foreign correspondent banking relationship. U.S. depository institutions often have to request additional information about the underlying activity in an FFI’s account in order to satisfy their risk-based obligations.

The post AML Regulation and Compliance Trends appeared first on Corruption, Crime & Compliance.

The New Voice of The Whistleblower

The Network Inc. GRC Blog -

Seven years after the launch of the U.S. Securities and Exchange Commission’s (SEC) whistleblower program, the voice of the whistleblower is starting to sound very different. It’s a little stronger, a little bolder, and a little louder. Learn what the landscape of modern whistleblower reporting looks like in 2018.

The New Voice of The Whistleblower

Ethics & Compliance Matters™ by NAVEX Global -

Seven years after the launch of the U.S. Securities and Exchange Commission’s (SEC) whistleblower program, the voice of the whistleblower is starting to sound very different. It’s a little stronger, a little bolder, and a little louder. Learn what the landscape of modern whistleblower reporting looks like in 2018.

Gerry Zack on What Led Him to The Society of Corporate Compliance and Ethics & Health Care Compliance Association [Video Podcast]

The Compliance & Ethics Blog -

By Adam Turteltaub On October 16, 2017 Gerry Zack was named as the Incoming CEO of the SCCE/HCCA.  Take a look at these videos (or listen in to the audio-only versions) to get to know Gerry. Part 1 In Part 1 he discusses his background in audit, fraud, and compliance.  He also shares his […]

Don’t Give Up Your Evidence during Employee Investigation Procedures

Loss Prevention Media -

The truth can be an elusive thing. Determining the truth can often be problematic even when there may be audiovisual evidence of what happened. Four cameras covered the slide of the runner as the third baseman took the throw and swung his mitt to touch the advancing runner. The umpire was carefully positioned and observed the play calling the runner out. The manager protested the call, and the umpires gathered to review the video evidence of the play. While the play was clearly close, after attempting to tag the runner out the third baseman pursued the runner reinitiating the tag when he reached third base. Immediately the announcers raised questions suggesting the third baseman had actually missed the tag. Depending on the camera angle, there was no independent verification that the umpire had blown the call. The end result? The base runner was out as the play was called.

.inline-text-ad h1, .inline-text-ad h2, .inline-text-ad h3 { margin-top: 0; } .inline-text-ad h1 { font-size: 18px !important; font-weight: bold !important; } .inline-text-ad p { font-size: 1.0rem; } .inline-text-ad { border-top: 1px dotted #cccccc; border-bottom: 1px dotted #cccccc; padding-top: 20px; } @media only screen and (max-width: 768px) { .inline-text-ad { text-align: center; } .inline-text-ad h1, .inline-text-ad h3, .inline-text-ad h3 { font-size: 1.15em; } } @media only screen and (max-width: 460px) { .inline-text-ad h1, .inline-text-ad h3, .inline-text-ad h3 { font-size: 1em; } } Find out where the real threat to your company lies by reading this FREE Special Report, Employee Theft: Statistics, Interviewing Techniques and Tips to Optimize your Employee Theft Policy.

Sometimes the truth can be altered because of the position of the observer. In this case, the third-base umpire was in the best position to closely examine whether or not the third baseman actually made contact with the runner. Fans who were biased for the runner argued the third baseman’s actions after the attempted tag showed that he believed he had missed touching the runner.

So the truth can change as a result of biases, assumptions, position, or other qualifiers, which might shade even the truthful witness’s testimony. Many times the guilty individual will intentionally shade the truth in an attempt to salvage his self-image or to reduce the seriousness of what he has done.

During employee investigation procedures, it is often difficult to know with absolute certainty what the real truth might be. Instead, the investigator has to use the physical evidence, witness testimony, or other information to piece together what is the most likely series of events.

Don’t Give Up Your Evidence during Employee Investigation Procedures

Since it can be difficult to tell when people are lying, shading the truth, fabricating events, or just omitting details that may incriminate them, the investigator can use what evidence is available to evaluate the stories, sequence of events, or alibis of the main players.

If the individual was aware of all the information available to the investigator, he could begin to alter his story to match the evidence uncovered during the investigation. However, when the investigator withholds the evidence and allows the individual to tell his story, the evidence can help determine the veracity of the individual. One common problem during conversations with those suspected of wrongdoing is that the investigator contaminates a confession by talking about evidence, alluding to evidence, or using leading questions that infer the correct answer.

Evidence can also be given up by using an incorrect assumptive question to obtain the first admission. For example, if the subject is suspected of creating fraudulent refunds to steal money, many investigators might ask for the first admission using this question—“What is the most number of fraudulent refunds you created to take money from the company?”

If one was to use an assumptive question relating directly to the refund, you have indirectly told the subject what is most likely known and where his exposure in the investigation lies. This question may also infer that the investigator does not know about any other forms of cash thefts the employee has participated in. This results in the employee making fewer admissions because he doesn’t believe the investigator knows about the other areas of theft.

Had the investigator used an assumptive question that said, “What is the most amount of money that you took from the company in the last year?” This question addresses a broad area of the investigation, which has revealed the dishonest employee stole money but not the method used to do so. The employee may now offer an admission to taking money right out of the register or voiding sales leaving the investigator with his knowledge of the individual using fraudulent refunds to steal cash. The investigator now knows in absolute terms that the employee is lying by omission, and there is additional development of the admission to be done.

In any interview where the individual confirms facts that were not related to him by the investigator, it helps substantiate that the subject is giving a truthful confession.

Read the full article, “Random Lessons from the Room: Part One,” for more tips on identifying problematic interview strategies and indicators of theft activity. The original article was published in 2017; this excerpt was updated January 16, 2018.

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Creating a Culture of Compliance

Program on Compliance and Enforcement, New York University School of Law -

by Michael C. Neus

Many constituents have a vested interest in determining a firm’s culture of compliance:  regulators, investors, prospective employees, among others.  Investment advisers registered with the Securities and Exchange Commission must demonstrate their compliance culture during periodic examinations by the Office of Compliance, Inspection and Examinations.  Current and former SEC examination staff often state that the primary indicator of a healthy compliance culture is the “tone from the top.”  There are a number of steps that a firm can take to demonstrate that top management fosters an effective compliance culture.

  1. Unitary Policies and Procedures. Healthy firms have rules that apply to all employees, regardless of seniority.  The Chief Compliance Officer should be able to demonstrate that senior management is subject to all the same company rules.  For example, if a firm requires preapproval of employees’ securities trades, the CCO should maintain a list of trades of each senior manager with the appropriate preapproval form authorizing the trade.
  2. Penalties and Recidivism. Compliance policies and procedures need to have teeth in order to be effective.  Compliance violations should carry consequences.  When violations have no effect, employees will violate policies if they view violations to be in their interest.  Penalties should escalate for the seriousness of the violation, as well as for repeated violators.  For example, a warning may be the appropriate penalty the first time an employee fails to preapprove a trade if it is an inadvertent oversight.  However, if an employee deliberately front-runs his own portfolio, or habitually fails to seek preapproval, the penalty should be more severe, such as a monetary fine or even termination.
  3. Hiring Practices. Recruiters and hiring managers should overtly understand that personal integrity is a key attribute for any successful recruit.  Potential employees should be asked hypothetical compliance questions to gauge their ethical compass.  All employees should undergo background checks, including internet searches to determine unusual patterns of behavior.   Personal reference checks should seek to evince the applicant’s attitudes toward compliance policies as well as core competency and cultural fit.
  4. Training. Employee training should be effective and frequent—not rote and unimportant.  New employees should have a compliance training session on their first day.  That ensures that no employees can say that they didn’t know the rules, didn’t think the firm cares about its policies and procedures, or didn’t know whom to ask about how compliance rules apply in specific situations.  Training should be tailored to the specific risks identified by the compliance department—for instance a firm specializing in fundamental securities research target training on avoiding insider trading.  Employees should see that senior managers are subject to the same training policies.  Failure to take compliance training seriously should have consequences.
  5. Incentives. People tend to do what they are incented to do.  Corporate culture must incentivize compliance with firm policies.  For instance, employees should be penalized for failing to seek guidance from the compliance department over a questionable tip, rather than penalized for getting the firm restricted in a security.  Annual and semi-annual employee evaluations should give a rating on employee cooperation with the compliance department.  And that rating should actually matter when considering bonuses and promotions of employees.
  6. Resolving Conflicts of Interest. In every firm, there will be conflicts of interest: Conflicts between laws and rules of different jurisdictions (GAAP vs. Investment Advisers Act).  Conflicts of principles (duty to disclose vs. fiduciary duty to protect clients’ interests).  Conflicts among clients (trade allocation decisions).  Often there are conflicts where there are no clearly good answers.  Sometimes it is a question of which is the least bad outcome.  The Chief Compliance Officer should document the thought process and legal advice received when resolving the most vexing conflicts.
  7. Aligning Interests.  If senior management truly want a culture of high integrity, they have to “walk the walk” as well as “talking the talk.”  When employees are singled out positively for contributing to a compliant culture other employees notice.  Similarly when firms promote and reward highly productive employees well known for ethical lapses, other employees instinctively understand what management truly values.  There is no short-cut to creating a culture of compliance.  The tone from the top, is exactly that.  What do top management truly value, and how do they communicate those values to the rank-and-file.

Michael C. Neus is a Senior Fellow with the Program on Corporate Compliance and Enforcement at New York University School of Law.  He is the General Counsel of ExodusPoint Capital Management, LP.   In addition, Mike teaches a course entitled “Investment Management Regulation and Compliance” at Fordham Law School.

The views, opinions and positions expressed within all posts are those of the author alone and do not represent those of the Program on Corporate Compliance and Enforcement or of New York University School of Law.  The accuracy, completeness and validity of any statements made within this article are not guaranteed.  We accept no liability for any errors, omissions or representations. The copyright of this content belongs to the author and any liability with regards to infringement of intellectual property rights remains with them.

Breaking News in the Industry: January 16, 2018

Loss Prevention Media -

Watch shoplifter steal jewelry from retailer in New Orleans [Viral Video]

The owner of a Magazine Street boutique is asking for the public’s help to identify a man who she says stole about a thousand dollars worth of jewelry from her store. The unidentified man pocketed rings from Century Girl Vintage, 2023 Magazine St., New Orleans, on Wednesday (Jan. 10), owner Leah Blake said.  An employee said the man entered the store just before closing. In surveillance video, he can be seen casually walking to the rear of the store and grabbing items that he doesn’t put back. “He was just picking up rings like you would pick eggs on a farm,”  A relative who was waiting to give the employee a ride home noticed the man enter the store and thought it was suspicious for him to be visiting a women’s boutique at closing time, according to Blake.

The relative came inside and chatted up the man to make sure the employee was OK, Blake said. “He was really charming and talkative,” she said. When asked where he was from, the man hesitated before saying he was visiting from Dallas. However, Blake’s employee and the relative noted he had a New Orleans accent and was wearing a New Orleans Saints shirt.  “He clearly had a New Orleans, kind of y’at accent,” Blake said. In sharing details about the theft in a Magazine Street business forum, Blake learned that a shoplifter with a similar description had stolen jewelry from Sterling Silvia, 3110 Magazine St. An employee at Sterling Silvia confirmed Sunday that the business had posted a photograph of the shoplifter on the front door. It’s not clear what was stolen from that store. At Century Girl, the shoplifter took a 14-karat gold lion ring with emerald eyes and two vintage silver rings from the 1920s, one with an aquamarine stone and another with a synthetic sapphire, Blake said. “It’s just awful when it happens to small businesses,” she said. [Source: The Times Picyune]

Jason’s Deli: Data Breach Could Affect 2 Million Cards

Hackers have struck the quick-service industry again. Jason’s Deli announced that a “large quantity of payment card information” was being sold on the dark web, and at least a portion of the data was pulled from Jason’s Deli locations. While the investigation is still underway, as many as two million credit card numbers may have been compromised. The company was notified December 22 and said, “management immediately activated our response plan, including engagement of a leading threat response team, involvement of other forensic experts, and cooperation with law enforcement.” Jason’s Deli said RAM-scraping malware targeted a number of its point-of-sales systems at corporate-owned locations beginning June 8. The brand said the security breach has been contained. “While this information varies from card issuer to card issuer, full track data can include the following: cardholder name, credit or debit card number, expiration date, cardholder verification value, and service code.

However, it should be noted that the cardholder verification value that may have been compromised is not the same as the three-digit value printed on the back of certain payment cards (e.g., Discover, MasterCard, and Visa) or the four-digit value printed on the front of other payment cards (e.g., American Express). In addition, the track data does not include personal identification numbers (“PINs”) associated with debit cards,” Jason’ Deli said in a statement. Jason’s Deli is the latest restaurant company to face a breach. This past October, Pizza Hut announced that a “small percentage” of its customers were affected by a “temporary security intrusion.” In September, Sonic Drive-In revealed that it was the target of a security breach. In May, Chipotle announced a security issue hit “most” of its locations. Arby’s said in February that potentially more than 355,000 customers’ credit cards could have been compromised. More than a thousand Wendy’s locations were impacted by a major card breach in July 2016, an issue that proved costly for card-issuing banks and credit unions, KrebsOnSecurity points out. Wendy’s needed months to fix the situation, partly because of the brand’s large corporate-owned structure.[Source: QSR Magazine]

Woman charged with shoplifting allegedly tried running down officers in car

A woman reportedly led Great Falls police on a chase on Tuesday, nearly striking three officers’ cruisers pursuing her for allegedly shoplifting items from Shopko. Samantha Wise was arrested the next day at the home of her friend, Derek Xavier Nisbet, who was also arrested for hiding a person wanted by police.  According to court documents, Shopko alerted police to a shoplifting incident on Jan. 9, claiming a man, later identified as Nisbet, left on foot while a woman, who police identified as Wise, left in a vehicle with stolen items.

Police located Nisbet at West Bank Park allegedly in possession of items shoplifted from Shopko, while an officer later found the SUV, reportedly stolen, Wise was driving near the 700 block of 6th Street Northwest, according to court documents.  When approached by a police cruiser, Wise reportedly smiled and flipped him off before driving directly at the officer, who had to step out of the way to avoid being hit, charging documents state. Later on, another officer on Central Avenue West reported Wise entered his lane and drove directly at the officer who was trying to turn around to initiate a traffic stop. The officer had to veer into a different lane to avoid being struck, charging documents state. [Source: Great Falls Tribune]

Supermarket employee accused of stealing $8,000 over a year

A Giant Food Store employee is accused of stealing approximately $8,000 in cash from the Lower Saucon Township supermarket over a period of about a year. In a news release Thursday, township police said Toska Slotter, 42, of Hellertown, “admitted to committing the thefts,” which police say occurred between Jan. 24, 2017 and Jan. 7, 2018 at the 1880 Leithsville Road store. Police said they were alerted to the alleged thefts by Giant Asset Protection. At the time of her interview with police, authorities say Slotter “was also found to be in possession of three different controlled substances–Adderall, Methadone and Suboxone–without a prescription.” After being arraigned before District Judge Roy Manwaring Wednesday on charges of theft, receiving stolen property and possession of a controlled substance, Slotter was released on $15,000 unsecured bail, police said.  [Source: Socuan Source]

Woman gets jail for 2016 retail fraud

A Wilson, Michigan, woman, who failed to appear for her sentencing nine months ago, was sentenced in Delta County Circuit Court on Friday in connection with the theft of merchandise from two Escanaba stores in 2016.  Melissa Rose Meshigaud-Ritchie, 37, was sentenced to 90 days in jail on one count of conspiracy to first-degree retail fraud, a five-year felony, which she pleaded guilty to in early 2017 but failed to show for sentencing last April. Meshigaud-Ritchie was arrested in December 2016 along with co-defendants Veronica Mae Williams, 28, and Manitoubani Wandahsega, 35, all of Wilson, for stealing nearly $3,000 worth of security systems and miscellaneous merchandise from Menards and Dunham’s Sports earlier that month.

According to Escanaba Public Safety, the three removed items from the stores through doors that were locked from the outside but not the inside. In February 2017, Meshigaud-Ritchie pleaded guilty to conspiracy to first-degree retail fraud but failed to appear for her April 24 circuit court sentencing and was charged with contempt of court. During her sentencing Friday, Meshigaud-Ritchie was given credit for serving 55 days in jail. The balance of her 90-day sentence was suspended due to her having a serious medical condition. She admitted in court she was drunk when the theft occurred and she nearly died in jail due to her health issue. She was placed on probation for 12 months and ordered to have no alcohol or illegal drugs and cannot enter bars. She must undergo drug testing. She was also ordered to have no contact and not be within 500 feet of Menards or Dunham’s. In addition to being fined $1,028 in court costs, Meshigaud-Ritchie was ordered to pay joint restitution with Wandahsega and Williams including $2,399 to Menards and $434 to Dunham’s. [Source: Daily Press]

Store employee charged in shoplifting $3,280 in merchandise; cash

An employee at a Florida Dollar Star, a low-priced close-out store located inside the Merritt Square Mall, was taken into custody Wednesday after deputies said he had stolen thousands of dollars worth of items and took cash from the register over a period of seven weeks.  After the manager of Dollar Star confronted Derek Anthony Jeter, 20, with accusations the employee was shoplifting, Jeter provided the manager a written statement outlining items he had stolen, according to reports.  Unlike the $1-only Dollar Store, at Dollar Star, you can buy luggage for $40. But most items in the store are under $10. When deputies made contact with the Cape Canaveral man, he told them he had taken food, drinks and clothes from the store. He also took money from the cash register and carried out fraudulent returns to pocket the money, according to deputies.  This went on for seven weeks, totaling about $3,280 in items, cash and fraudulent transactions, deputies report. Jeter was booked into the Brevard County Jail with bail set at $4,000. [Source: Florida Today]

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Two Michigan Residents Injured in Fatal Indiana Police Chase after Retail Theft

Loss Prevention Media -

Two Michigan residents were injured, one critically, when their SUV was struck by a teenage driver being pursued by Indiana State Police after an alleged theft from a Meijer store. Miguel Linares Jr., 34, of Bloomfield Hills, suffered potentially life-threatening injuries in Saturday night’s collision in Warsaw, Indiana., police said. His passenger, Nora Linares, 35, also of Bloomfield Hills, suffered serious injuries.  Both were being treated at Parkview Hospital in Fort Wayne. The incident began about 9:20 p.m. Saturday when an Indiana state trooper responded to a reported theft at a Meijer store in Warsaw. Authorities said the trooper saw a Pontiac Grand Am matching the suspect vehicle’s description and attempted to stop it, but it fled east on U.S. 30. It drove through a red light at the intersection of the highway and Parker Street, crashing into three other vehicles, including the one driven by Miguel Linares. The two occupants in the Grand Am both died. The driver was identified by police as Jacob Slone, 19. The passenger was identified as Paige Jefferson, 16. Both were from Warsaw. [Source: Mlive]

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Day 16 of 31 Days to a More Effective Compliance Program-the Third-Party Risk Management Process

FCPA Compliance & Ethics -

As every compliance practitioner is well aware, third parties still present the highest risk under the Foreign Corrupt Practices Act (FCPA). The Department of Justice Evaluation of Corporate Compliance Programs devotes an entire prong to third party management. It begins with the following: Risk-Based and Integrated Processes – How has the company’s third-party management process [...]

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Annual Data Privacy Day to Focus on Safeguarding Data

Risk Management Monitor -

Last year was certainly a turning point in the history of online privacy and cyber security. Between ransomware attacks, the Equifax breach and the Federal Communication Commission’s vote to repeal net neutrality regulations—just to name a few high-profile incidents in the United States—businesses and citizens have more reasons than ever to safeguard their information.

To address this important issue, the annual Data Privacy Day (DPD) will be held Jan. 28, with online and in-person events leading up to it now that celebrate individual users’ rights to privacy and aim to prevent cyber theft and risk. DPD has been led by the National Cyber Security Alliance (NCSA) in the U.S. since 2011 and “highlights our ever-more connected lives and the critical roles consumers and businesses play in protecting personal information and online privacy,” said NCSA Executive Director Michael Kaiser.

DPD was created to commemorate the 1981 signing of Convention 108 by the Council of Europe and is observed by more than 47 countries. It was the first legally binding international treaty dealing with privacy and data protection and officially recognized privacy as a human right. NCSA also co-hosts National Cybersecurity Awareness Month and the Department of Homeland Security’s Stop.Think.Connect. campaign, which aims to increase the public’s understanding of cyber threats.

“Our personal information and our habits and interests fuel the next generation of technological advancement, like the Internet of Things, which will connect devices in our homes, schools and workplaces,” Kaiser said. “Consumers must learn how best to protect their information and businesses must ensure that they are transparent about the ways they handle and protect personal information.”
On Jan. 25, LinkedIn will live-stream an event from its San Francisco office exploring the theme of “Respecting Privacy, Safeguarding Data and Enabling Trust.” The broadcast will feature TED-style talks and panel discussions with experts focusing on the pressing issues that affect businesses and consumers. Additional DPD happenings include Twitter chats and networking gatherings to maintain a dialogue about the importance of privacy rights.
The relevance does not end on Jan. 29, noted Richard Purcell, DPD advisory board member and chief executive officer of Corporate Privacy Group. He has witnessed the event’s evolution and its impact on risk management and privacy professionals.

“The community of privacy professionals is not made up of private people. They want to share information,” noted Purcell, who was named Microsoft’s first corporate privacy officer in 2000. “They initiate a dialogue that the officers bring back to their companies. I have seen how it has stimulated events inside corporations and universities that were inspired by Data Privacy Day networking discussions. The professional development aspects of the day are profound.”
Newly released information from NCSA demonstrates how privacy is impacted in both personal and professional environments—from healthcare and retail to social media, home devices and parenting. Some statistics include:

  • In 2016, 2.2 billion data records were compromised and vulnerabilities were uncovered in internet of things products from leading brands.
  • 41% of Americans have been personally subjected to harassing behavior online and nearly one in five (18%) has been subjected to particularly severe forms of harassment online, such as physical threats, harassment over a sustained period, sexual harassment or stalking.
  • Nearly one-third of consumers do not know that many of the “free” online services they use are paid for via targeted advertising made possible by the tracking and collecting of their personal data.
  • About 78% of respondents to a recent survey of healthcare professionals said they have had either a malware and/or ransomware attack in the last 12 months.

Customs Fraud, Wildlife Crime, and the Value of Whistleblowers

Whistleblower Protection Blog -

In late 2017, federal prosecutors in the Southern District of New York (considered one of America’s most important judicial districts) settled a case against Notations, a garment wholesaler. In a case originally brought by a qui tam relator (a.k.a. a whistleblower), Notations admitted to ignoring repeated warning signs that its Chinese importer was lying about the value of its imported goods to avoid paying customs fees. As a result, Notations has agreed to pay $1 million in fees.

While the Department of Justice did not release the portion of the award that went to the whistleblower, under the False Claims Act a whistleblower plaintiff is entitled to somewhere between 15% and 30% of the total reward.

The principles of this case can and should be applied to the wildlife crime context. As Stephen M. Kohn, Executive Director of the National Whistleblower Center, explained in his award-winning article, expanded use of wildlife whistleblowing could be a boon to animals and the environment. Criminal networks that import wildlife have been known to falsely label their animal products when they enter the country. This is a crime. Customs officials need to be trained to detect such fraud and prosecutors should seek to bring more wildlife crime cases.

The False Claims Act and other laws with whistleblowers provisions like the Lacey Act have the potential to be powerful tools for unearthing wildlife crime. NWC, as a part of its mandate as a Grand Prize Winner of the Global Crime Tech Challenge, is promoting the existence of these reward laws and has a global wildlife program to inform wildlife whistleblowers of their rights.

The Notations case demonstrates how falsified customs documents, whistleblowers, and the False Claims Act intersect. The next frontier for such cases should be wildlife crime.

Read the full DOJ press release here.

Why a Retail Theft Database Might Keep Your Staff Safe

Loss Prevention Media -

Retail loss prevention professionals know that organized retail crime (ORC) is a threat not to be taken lightly. But statistics are showing aggressive offenders are on the rise. How are you keeping your store teams safe?

In an article for the December issue of LPM Online, Phil Thomson, CEO of Auror, explores why a lack of intelligence about the most dangerous offenders is one of the biggest obstacles faced by LP teams today.

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Get the facts about shoplifting in our FREE Special Report,Tips on How to Stop Shoplifting:   What You Can Learn from Shoplifting Statistics, Organized Retail Crime Facts & Shoplifting Stories right now!

We have the technology to collect information on existing crimes, so why aren’t we combining it with other useful data points in a retail theft database designed to help LP teams predict and prevent ORC events? From the article:

Chances are your store teams are reporting crime at your stores already. But current crime reporting processes don’t enable this sort of prevention‐first mindset. It’s about reporting a crime to someone else, so they can do something about it.

These reports hold a wealth of intelligence that can be unpacked to help identify the patterns of offending, associated offenders, vehicles used in the commission of crimes, and more. So the value of crime reports isn’t always necessarily in their ability to solve an individual crime, but in their ability to connect the dots to help prevent and solve other related crimes as well. When combined with other data points in real time, these reports can uncover a myriad of actionable intelligence that the right people can use at the right time to prevent further offending.

Read more about what happens when retailers begin to use intel collection to accurately prevent crime in “Intelligence: The Most Important Tool in the Fight Against ORC” (sponsored by Auror). If you’ve missed any of our previous LPM Online editions, go to the Archives page at the end of the edition to see what you’ve missed. Be sure to be an LPM digital subscriber so you are the first to know when new issues are available. If you haven’t already, sign up on the SUBSCRIBE NOW link. (Note: if you’re already subscribed, the previous link will take you to the current issue of the print magazine.)

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Delaware’s Prudent Approach to the Cleansing Effect of Stockholder Approval

The Harvard Law School Forum on Corporate Governance and Financial Regulation -

Posted by William Savitt, Wachtell, Lipton, Rosen & Katz, on Tuesday, January 16, 2018 Editor's Note: William Savitt is a partner at Wachtell, Lipton, Rosen & Katz. This post is based on a Wachtell publication by Mr. Savitt, Ryan A. McLeod, and Anitha Reddy, and is part of the Delaware law series; links to other posts in the series are available here.

In Corwin v. KKR Financial Holdings LLC, 125 A.3d 304 (Del. 2015), the Delaware Supreme Court held that a non-controlling stockholder transaction approved by informed, unaffiliated stockholders is protected by the business judgement rule and that any lawsuit challenging such a transaction should be dismissed absent well-pleaded allegations of corporate waste. Recognizing that today’s sophisticated stockholder body can and does protect its own interests, Corwin held that in the great run of cases, stockholders—rather than plaintiffs’ lawyers or courts—should have the last word.


2017 Year in Review: Securities Litigation and Regulation

The Harvard Law School Forum on Corporate Governance and Financial Regulation -

Posted by Jason Halper, Kyle DeYoung and Adam Magid, Cadwalader, Wickersham and Taft LLP, on Tuesday, January 16, 2018 Editor's Note: Jason Halper is partner and Co-Chair of the Global Litigation Group, Kyle DeYoung is partner, and Adam Magid is Special Counsel at Cadwalader, Wickersham and Taft LLP.  This post is based on a Cadwalader publication by Mr. Halper, Mr. DeYoung, Mr. Magid, Jared Stanisci, James Orth and Aaron Buchman.

The securities litigation and regulatory landscape in 2017 defies simple categorization. Plaintiffs filed 226 new federal class actions in the first half of 2017, more than double the average rate over the last 20 years, and an additional 99 federal class actions in the third quarter of 2017. In contrast, new SEC enforcement proceedings declined. After staying on pace with the prior two years with 45 new enforcement actions against public company-related defendants in the first half of fiscal year 2017, the SEC filed only 17 new enforcement actions against public company-related defendants in the second half of the year. The apparent decrease in initiation of enforcement proceedings coincides with the arrival at the SEC of Chairman Walter J. Clayton, who has expressed the view that enforcement actions against issuers rather than individual wrongdoers too often punish the very investors they seek to protect.


How Transparent are Firms about their Corporate Venture Capital Investments?

The Harvard Law School Forum on Corporate Governance and Financial Regulation -

Posted by Sophia J.W. Hamm (The Ohio State University), Michael J. Jung (New York University), and Min Park (The Ohio State University), on Tuesday, January 16, 2018 Editor's Note: Sophia J.W. Hamm is Assistant Professor of Accounting at The Ohio State University Fisher College of Business; Michael J. Jung is Assistant Professor of Accounting at NYU Stern School of Business; and Min Park is a PhD candidate at The Ohio State University Fisher College of Business. This post is based on their recent paper. Related research from the Program on Corporate Governance includes Carrots & Sticks: How VCs Induce Entrepreneurial Teams to Sell Startups, by Jesse Fried and Brian Broughman (discussed on the Forum here).

Corporate venture capital (CVC) refers to direct minority equity investments made by established, publicly-traded firms in privately-held entrepreneurial ventures. CVC investing differs from pure venture capital investing in that financial returns are not the primary consideration, but rather, strategic gains are often the driving motivation to invest. While established firms in the technology, industrial, and healthcare sectors such as Google, General Electric, and Johnson & Johnson have set up CVC subsidiaries to invest billions of dollars in startups, younger firms such as Twitter with relatively smaller cash balances are starting to engage in venture capital investing as well. According to data from CB Insights, firms’ CVC investments in the U.S. were $17.9B in 2015 and $16.1B in 2016, involving 1,603 deals that accounted for nearly one-fifth of overall venture capital deals. CVC investments are now at the highest levels since the dot com era. The motivating research questions we are interested in examining in this setting are: 1) how transparent are firms about their CVC investments, and 2) is CVC investing a productive use of a firm’s capital resources?


Michael Garland: Boardroom Accountability

Corporate Governance -

Michael Garland: In the News Michael Garland, his boss Scott M. Stringer and the New York City Pension Funds are setting a higher bar for corporate boards and other funds with regard to corporate governance standards. I wish more would try to do half as much for shareholders. Their Boardroom Accountability Project was responsible for much […]

The post Michael Garland: Boardroom Accountability appeared first on Corporate Governance.

Successful divestitures

Ethical Boardroom Feeds -

By Paula Loop, PwC partner and the leader of PwC’s US Governance Insights Center & Catherine Bromilow, PwC partner in PwC’s US Governance Insights Center


Focussing on growth is a given when it comes to increasing value for a company’s investors. That can mean exploring an acquisition or a strategic alliance. But expanding isn’t the only way to unlock shareholder value.

Some companies have businesses that don’t contribute to core capabilities or fit with their current strategy. Perhaps a previously acquired company wasn’t integrated successfully. Perhaps a business is a drag on earnings because its financial performance lags other businesses. Or a thriving business may have outgrown the parent company and could be more valuable either on its own or as part of another company. By removing nonconforming businesses, a company can create a more focussed portfolio for shareholders.

Shareholder activists also often urge target companies to divest parts of their businesses. In 2016, activist hedge funds had US$176billion in assets under management and publicly targeted 329 public US companies, according to Activist Insight Annual Review 2017. As of July 2017, there were 91 US activist campaigns that called for companies to explore some type of sale process, more than double the number called for in the previous year.[1] See chart below (note, all deals of more than $100billion have been excluded). And with the money that has been flowing into activist hedge funds – at least in the United States – we expect such pressures to continue.

Any potential divestiture should be aligned with a company’s overall strategy and plans to create long-term value. Boards that understand the strategy and how each part of the company does or doesn’t contribute to it will better serve their shareholders.

Divestitures can be challenging. A company must identify the business unit to be separated, decide on the type of separation and either prepare it for sale or develop a standalone entity that will function outside of the parent. A divestiture ultimately is a surgical procedure, with a degree of complexity that demands careful planning and caution.

Boards should discuss with management the goal of any major proposed divestiture. That should include how removing a business unit will allow the company to do something it can’t do today. Once directors are satisfied with the strategic reasons for divesting, they can consider other important questions for the board, including:

  • What kind of divestiture should we consider?
  • How important is timing?
  • How are we handling talent?
  • What should our board watch out for after a deal is done?

What kind of divestiture should we consider?

Companies have multiple options for divesting a business unit and may choose to either maintain some type of connection with the divested unit or sever all ties. Depending on the exit structure, the regulatory, tax and financial reporting requirements can vary significantly and usually involve different timetables.

In a carve-out IPO, a company separates a business unit or subsidiary but offers only a minority interest in the new entity to outside investors. The result is two separate legal entities, each with its own financial statements, management team and board of directors. The parent company retains a controlling interest in the new company

A spin-off creates an independent company with its own equity structure, with shares in the new company typically distributed to the parent company’s shareholders. Unlike a carve-out IPO, the parent company doesn’t have a controlling interest and instead holds no equity or possibly a minority stake

A split-off is similar to a spin-off in that it also creates a new entity with its own equity structure and the parent company doesn’t have a controlling interest. The difference is that shareholders can essentially exchange shares in the parent company for shares in the new company. A split-off can have a less dilutive effect than a spin-off on the parent company’s earnings per share

A trade sale typically is the cleanest type of divestiture. A company completely turns over a subsidiary or business unit to another company, a private equity firm or some other buyer. A sale is usually easier and faster to complete than the other types of transactions

A parent company may contribute a portion of its business to form a joint venture (JV), with or without control. This kind of transaction can unlock synergies with a partner and provide access to other assets when other transactions may not be available. For board considerations when management is considering an alliance, see PwC’s paper Building Successful Alliances And Joint Ventures

How important is timing?

Different types of divestitures typically take different lengths of time to complete. That matters if a company needs to separate a business quickly because of broader company concerns or market issues. A sale usually takes the least amount of time – anywhere from a few months to a year. If a company needs to secure capital, reduce expenses or make some other financial or strategic move in the short term, it may be limited to contemplating a sale because other deals would take too long.

“Different types of divestitures typically take different lengths of time to complete. That matters if a company needs to separate a business quickly because of broader company concerns or market issues”  

A sale still raises key considerations for the board – notably, how to maximise value for shareholders. Management should tell directors if there’s a specific buyer in mind or if the business unit will be marketed to a wide range of possible buyers. Private equity buyers may have different requirements or conditions than corporate buyers. If the potential buyer is another company, the board should know if it’s in the same industry and be able to share any concerns it might have with management.

Carve-out IPOs, spin-offs, split-offs and JVs take longer to finalise – sometimes more than a year. Forming a new entity involves legal, regulatory and other requirements that simply selling a business to a buyer doesn’t. Without adequate resources, the transaction could become a distraction that affects day-to-day operations – and the board should discuss this with management ahead of time.

Before the company embarks on a divestiture, directors should ensure management has or will hire the right people to handle the heavy lifting. The board also should be confident in management’s plan to keep the rest of the company running effectively and employees engaged in their work.

How are we handling talent?

Depending on the type of divestiture, talent can be a relatively small issue or a more complex concern. In a sale, the business unit’s employees and leaders often stay in their existing roles as the business moves to new ownership. But the divesting company may want to retain certain talent, such as executives with senior leadership potential. Board members should be aware of those conversations and make sure such pursuits don’t jeopardise the transaction. Once the sale is completed, personnel and development issues become matters for the new owner.

Talent decisions are typically more complicated with carve-out IPOs, spin-offs, split-offs and JVs. Because parent company shareholders typically still have some level of investment in the new entity, boards should have a stronger interest in decisions about employees and leaders.

The board should ask management if the managers of the business unit being separated are willing and able to lead an independent company. If not, directors should discuss how new talent will be brought in.

Talent migration is complex, particularly for employees working outside the separating business unit, such as finance or IT. People attached to the divested business can expect to be affected. The transaction also could pull employees from these enterprise functions. Management needs to be strategic about who stays and who goes.

“With the right understanding and planning, companies that are considering a divestiture in a dynamic market can achieve strategic goals and ultimately deliver greater value for their shareholders”

Employees in these functions may question management’s decision to shift their employment to the new entity and some could choose to leave for jobs elsewhere. To retain them, management may need to offer compensation, career development opportunities and other incentives, such as stay bonuses. Management will also have to address deferred compensation for the individuals who are going to the new entity. The parent company board should ensure that leaders are equipped to communicate the rationale behind talent decisions.

Understanding at the start of the process where talent gaps will exist – both in the parent and separating companies – provides for more time to plan for the necessary incremental hiring from outside the companies. A divestiture also can affect employees and managers who aren’t directly involved in the transaction. The board should confirm that management is keeping the entire company in mind and has a comprehensive communications plan for the entire deal cycle.

For example, in some deals the selling company signs a transition service agreement (TSA) to provide certain services and support for a certain period after the deal closes. A seller with a TSA may need to maintain the resources to provide essential services in areas, such as finance and accounting, human resources (HR), legal, information technology (IT) and procurement. In some cases the TSAs may last more than a year.

What should our board watch out for after a deal is done?

A successful divestiture means going beyond executing the details of the transaction and taking the necessary legal steps to separate a business from the company. It requires putting both companies on the right trajectory for profitability and growth in the years following the deal.

This means striking the right balance when it comes to changes post-deal. If the new entity and parent company make only slight adjustments in strategy and operations, they run the risk of simply being smaller versions of the formerly combined company, with stranded costs and few, if any, new advantages. But if the two entities go to the other extreme and make drastic shifts, it could make the divestiture process even more complex and overwhelm the companies. The board can help by engaging management on the divestiture plan and, if it’s not a full sale, ensuring that it will leave both companies in competitive market positions.

One short-term challenge for the new entity after the transaction closes is the cost of establishing and managing processes and personnel that had been covered by the parent company. Those costs could be high, especially in the early months. The board should make sure there’s a cost-mitigation plan in place before the split.

The board also can help shareholders in the carve-out IPO, spin-off, split-off or JV understand how those added costs ultimately will be offset over time. Directors should understand how the divestiture may create opportunities for long-term value in both companies.

A divestiture can impact the original company, especially groups that support the enterprise. Large divestitures can leave the remaining company with more personnel than needed in some areas (e.g. HR, legal, IT). The board should discuss with management if the company will need to restructure to stop paying for services that are no longer needed once the TSA term is over.

The board should also discuss with management whether the divestiture process could make the company vulnerable to competitors. With highly visible and/or complex separations, other companies could see an opportunity to disrupt customer relationships and grab market share. Management should explain to the board how the company will provide business as usual for customers.

In conclusion

Done right, a divestiture can maximise shareholder value for all companies involved. The board of directors can play an important role in providing guidance at different stages of these complex transactions. With the right understanding and planning, companies that are considering a divestiture in a dynamic market can achieve strategic goals and ultimately deliver greater value for their shareholders.

For deeper insights into the board’s role in divestitures, read PwC’s full publication When A Piece Of Company No Longer Fits: What Boards Should Know.[3]


About the Authors:

Paula Loop is the leader of PwC’s Governance Insights Center, which strives to strengthen the connection between directors, executive teams and investors by helping them navigate the evolving governance landscape. With more than 20 years of experience at PwC, Paula brings extensive knowledge in governance, technical accounting, and SEC and financial reporting matters to organisations. Paula is a well known speaker on a variety of governance topics. She has also been quoted in publications such as the Wall Street JournalFinancial TimesForbes and CNBC. In 2017 NACD Directorship magazine named her for the third consecutive year as one of the 100 most influential people in corporate governance in the United States. Paula is a Certified Public Accountant (licensed in New York) and is a graduate of the University of California at Berkeley with a B.S. in Business Administration.

Catherine Bromilow is a partner in PwC’s Governance Insights Center, which strives to strengthen the connection between directors, executive teams and investors by helping them navigate the evolving governance landscape. With more than 19 years of experience at PwC, Catherine has focused solely on corporate governance. Earlier in her career, she worked in internal audit at a major financial institution. Catherine has authored and contributed to many PwC governance publications, including the new Risk Oversight SeriesGovernance for Companies Going Public — What Works Best and Director-shareholder engagement: the new imperativesNACD Directorship magazine in 2017 named her for the eleventh consecutive year as one of the 100 most influential people in corporate governance in the United States.

Catastrophic Events Drive Innovation in the Reinsurance Market

BRINK News -

Recent major weather events in Australia, Mexico, the Caribbean and the United States, including three hurricanes that were Category 4 or greater, have resulted in catastrophe losses exceeding $100 billion for the third year on record.

But the large insured loss, currently estimated at a record $111 billion before accounting for National Flood Insurance Program losses and the California wildfires, has created a perfect opportunity for the reinsurance market to showcase its ability to adapt solutions to the unique risk profiles of individual clients.

The value of reinsurance as a capital substitute was apparent during the 2008 financial crisis, when debt and equity financing was difficult to obtain. In its place, the reinsurance market demonstrated its ability to protect balance sheets, manage earnings and reduce volatility. Now, the series of catastrophic events in 2017—earthquakes in Mexico and Hurricanes Harvey, Irma and Maria—is reminding corporations, primary insurers and reinsurers that (re)insurance is one of the most effective ways to protect corporate capital bases from these events.

The third quarter of 2017 is likely to be one of the costliest in the insurance industry’s history. While it is still early and loss estimates will likely fluctuate, total catastrophe losses of just $75 billion would mean a combined ratio of 106 percent for the world’s top 20 reinsurers, according to A.M. Best. Although there appears to be little risk to solvency, earnings of individual insurers will be impacted, and in some cases, excess capital positions and catastrophe budgets may be eroded, which could result in ratings actions.

Record Capital Levels

Fortunately, the U.S. property and casualty industry is sitting on record capital levels and the global reinsurance market adds another $427 billion, so the sector is well-positioned to absorb such losses. But despite years of low reinsurance rates and low interest rates that have reduced the industry’s profitability since the last material rate increase after Hurricane Katrina, we do not expect a similar price revision this time around. Reinsurers have built up cash during the recent favorable years, while capital-market investors seeking non-correlated investments, such as hedge funds and pension funds, have put record amounts of money into catastrophe coverages.

Harvey on its own will probably not require an increase of industry capital; the addition of the cumulative effect of the earthquake in Mexico and Hurricanes Irma and Maria, however, could create a capital event. Yet with abundant capacity—and, of course, depending on the final numbers—the aggregate impact may be a one-time firming of rates within specified regions or coverages or a halting of decreases that recently began to moderate as reinsurers’ margins approached breakeven. We also expect casualty reinsurance rates to continue their recent trend of declining year-over-year rate reductions.

Rise of Insurance-Linked Securities

Insurance-linked securities (ILS), which provide approximately $82 billion of the reinsurance industry’s capital base, will likely continue to generate demand and augment traditional reinsurer capacity. Though the recent events may provide the first real test of alternative capital, investors have indicated they are prepared to recapitalize or increase their current positions, and in some cases they already have.

Earthquakes and hurricanes provide an opportunity to define the viability and effectiveness of catastrophe bonds, creating either a day of reckoning or a day of glory for the ILS market.

Thus far, we have seen these catastrophe bonds demonstrate their effectiveness and serve their intended purpose. Of course, the eagerness of investors to return to the market may be tempered by a possible capital lockup. Until all claims are settled, investors’ assets collateralizing the transaction cannot be released, which could cause them to offset any new ILS capacity offered against these withheld funds. The ability to trade certain classes of cat bonds in the secondary market enhances their liquidity if funds are withheld. Insurance company sponsors are monitoring payout patterns compared to the traditional market. Any payment disputes from ILS investors could provide reinsurers an opportunity to demonstrate their value-add to clients.

The series of catastrophic events in 2017 is reminding corporations, primary insurers and reinsurers that (re)insurance is one of the most effective ways to protect corporate capital bases from these events.

Assuming the ILS market responds to these catastrophes as defined, this capacity will likely remain an integral part of insurers’ capital structure, even when interest rates rise. Most ILS issuances define interest rates as a risk spread on top of return on U.S. Treasuries or to LIBOR, so the asset class will remain attractive as interest rates rise. ILS is now very much ingrained in the overall risk community, creating a pool of diverse capacity collectively serving and supporting the (re)insurance industry.

Technological Innovation

Overall, we expect the reinsurance marketplace to remain vibrant and continue offering a full range of products, supporting growth in reinsurance purchasing in virtually all its forms. Industry capital is at an all-time high, and clients are expanding covers, fully leveraging a broader array of solutions as the industry modernizes in the face of technological innovation. In addition to transactional products, reinsurers and ILS providers are developing more comprehensive, consultative value propositions, such as capital advisory and enterprise risk management services. These offerings withstand market cycles and macroeconomic factors and provide insurance companies with a dedicated, informed partner to support new product development and growth initiatives. This creates opportunity by leveraging advanced platforms and innovative customized solutions, such as coverage features applying to specific industries or risks unique to specific clients.

Advanced Modeling Techniques

As economic growth and demographic patterns impact risk concentrations, advanced modeling techniques will help ensure sufficient vertical and horizontal reinsurance coverage to support post-event liquidity and close the protection gap, especially around historically difficult risks such as floods. Only 27 percent of those affected by Hurricane Harvey had flood insurance, and sustained industry profitability will depend on increasing global insurance penetration. Complex emerging exposures such as cyber and terror are also increasingly finding solutions in the reinsurance market, and optimal structuring of coverage can also minimize regulatory capital. By tapping a variety of capital sources, structures and modeling capabilities, insurers are matching more efficient, customized solutions to their unique risk profiles, whether they are focused on protecting earnings against attritional losses or shielding their capital base from catastrophe losses.

As the industry enters the 2018 renewal, the market remains strong with a variety of solutions to deliver the right capital to risks. Following the recent catastrophes, reinsurers are adjusting business plans for opportunities in marine, energy, flood and specialty lines of business. In today’s world of unprecedented disruption, the (re)insurance solution for managing capital and earnings is as relevant as its solution for severity protection.


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