On January 9, 2017, ACC submitted a letter to the United Kingdom Financial Conduct Authority (FCA) in response to regulations including the head of the legal function in the Senior Managers Regime (SMR). ACC argues the effort, aimed increasing accountability … Continue reading
Gatekeeper Liability
In Letter to OECD, ACC Urges Compliance Incentives, Settlements as Keys to Effective Anti-bribery Laws
On November 11, 2016, ACC and its Compliance & Ethics Committee submitted a letter in response to a consultation paper requesting public input on corporate anti-bribery laws from the Organization for Economic Co-operation and Development (OECD) Working Group on Bribery. … Continue reading
FILING UPDATE: NYDFS Affirms ACC’s Position Against Criminal Liability for Compliance Officers
The New York Department of Financial Services (NYDFS) affirmed ACC’s position on criminal liability for compliance officers in recently released anti-money laundering regulations. NYDFS significantly changed the compliance officer certification requirements, to which ACC had objected in a comment letter … Continue reading
ACC Files Comments Opposing Criminal Liability for Chief Compliance Officers
On March 31, 2016, ACC, its Compliance & Ethics Committee, Financial Services Committee, New York chapters, and 74 general counsel and compliance officers filed comments objecting to a proposal by the New York Department of Financial Services (DFS) to impose … Continue reading
Sanctions for Everyone? If One District Court Opinion Stands, Maybe.
Raise your hand if this is how your company runs its legal department: All in-house lawyers who might attend trials must have a thorough and precise knowledge of each and every one of the tens of thousands of documents that … Continue reading
