Tag Archives: compliance

Non-Federal Entities Receive Extra Year to Comply with Overhauled OMB Procurement Standards for Federal Assistance Agreements

Non-federal entities that receive federal assistance—such as colleges and universities, hospitals, nonprofits, and state, local and tribal governments—have been given an additional year to comply with the Office of Management and Budget’s (OMB) revised procurement standards for grants and federal funding. In December 2013, OMB overhauled its guidelines for the oversight and administration of federal … Continue Reading

How CFTC’s Aggressive Enforcement in 2016 Could Mold Compliance Efforts in 2017

U.S. Commodity Futures Trading Commission (“CFTC”) shook things up in 2016 with new theories and fresh interpretations of the law.  Along with this came hefty fines reaching up to $1.2 billion in total.  CFTC wasn’t the only regulatory group handing out large fines but the National Futures Association (“NFA”) also collected around $700,000.  Between the … Continue Reading

The Customs Compliance Letters and What They Really Mean

In late 2016, U.S. Customs issued an unusual letter to a select group of 1000 U.S. importers containing numerous compliance publications and detailing facts about the importers’ highest-valued goods. The letter asks for the importers to review CBP’s laws and regulations, and to either assure compliance or disclose in advance any errors identified. It also … Continue Reading

The Several Habits of Highly Effective Export Compliance Management Programs

When the U.S. State Department late last month announced the administrative debarment of a former senior export compliance officer from Honeywell International, Inc. (“Honeywell”), reports on and analyses of the event focused on the multiple allegations of what went wrong.  This was with good reason: any time a significant case of export noncompliance comes to … Continue Reading

At Last, The Bribery Act 2010 Adequate Procedures Guidance is Here

The waiting is over! At last the UK Ministry of Justice has published guidance about procedures which commercial organisations can put into place to prevent persons associated with them from bribing. The Act will now come into force on 1 July 2011. The guidance offers non-prescriptive procedures and commentary on the scope of the Act. … Continue Reading

The Bribery Act 2010 – What it means for you

This post was written by George Brown, Matt Stone, Simon Hart, Sarah Wolff, and Jim Sanders. The Bribery Act 2010 (the “Act”) which recently was passed by Parliament has far-reaching implications for any business which is either registered in the UK or which has any part of its operation in the UK. The breadth and importance … Continue Reading
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