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News & Views

The CLEAR Picture

September 2016 edition

In this issue

Best practices


cultureEstablishing a compliant culture: From a culture of compliance to a culture of integrity
Establishing a culture of compliance is a huge undertaking but an extremely worthwhile commitment. It takes continuous vigilance, resources and time to influence widespread change. As regulatory demands continue to grow, companies need to have the resources and technological framework in place to build compliance practices into their everyday workflow.
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handshakeTop ten things to keep in mind as your company considers whether or not to conduct business with an organization or individual
How important is it to know with whom you’re doing business? You don’t have to look very far for the answer; you’ve heard about the multimillion-dollar Ponzi schemes and government fines. In response, organizations across the country and globe are beefing up their due diligence programs and investing heavily to comprehensively guard against large monetary outlays and reputational calamity. In which areas should your company make the most significant changes due to FCPA guidance?
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digital lockStaying ahead of the curve on AML compliance: Ten points regulators will be looking for in your institution’s next exam
Anti-money laundering (AML) regulations and the compliance process have become more complex over the years for financial institutions. Identifying suspicious or criminal activity is important to each institution’s operations. Institutions’ AML programs have continued to mature and, concurrently, the expectations of regulators have increased. As financial institutions develop more sophisticated methods to identify suspicious transactions, high-risk customers, and sanctions violations, new areas of interest have been raised in examinations
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Spotlight


IranWhat has been the impact of relaxed sanctions against Iran?
January 16, 2016 marked the relaxation of certain sanctions against Iran, following the implementation of the Joint Comprehensive Plan of Action (JCPOA). Six months on, we assess the economic impact. The UN, EU, and the U.S. agreed to lift certain financial sanctions after Iran had implemented its nuclear-related commitments. However, specific sanctions do remain in force and others were imposed. It is still not always clear who may or may not conduct business with Iran, particularly for U.S. citizens and companies, or foreign subsidiaries of U.S. companies.
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Regulatory Trends


Jeremy ByellinImplementing the CDD rule in your small organization
It has been several months since the U.S. Department of the Treasury announced the final publication of the Customer Due Diligence (CDD) rule, and financial institutions continue to scramble to bring their organizations into compliance with the rule before it takes effect in May 2018. Of course, while large institutions may have the resources to meet the requirements of the CDD rule, many smaller financial firms may not, and consequently may instead be facing difficulties implementing and complying with the rule.
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