Bribery Enforcement Action in the Insurance Business……Again

The insurance industry looks to be a target. This would not be a surprise if you read my recent blog, Bribery and the Board in the Insurance Broker Business, here. With only days left in 2011, I won’t go so far as to use the (2011 word of the year, at least as per my list) contagion, but I have a feeling I will be using the term &ldqu...
Posted: 1/25/2012 2:01:05 PM by MS - Ryan | with 7 comments

Bribery and Anti-Corruption Enforcement Insurance in Canada

I speculate that the Governance, Compliance and Risk Management issue of Bribery and Anti-Corruption will go from a dusty item entered in to board minutes, to a material agenda item. This is not necessarily a good thing because none of the other agenda items can be easily de-weighted.As mentioned in previous blogs, CFPOA, Corruption of Forei...
Posted: 1/25/2012 1:58:39 PM by MS - Ryan | with 6 comments

Cybersecurity Disclosure …… No, Not Canadian Specific Guidance

Here is the Cybersecurity disclosure guidance being provided by the Division of Corporate Finance of the Securities and Exchange Commission.The good part is they don’t require disclosure that could act as a “roadmap” to infiltrate the registrant’s network security. And, in case you didn’t know your loss exposure...
Posted: 1/25/2012 1:56:46 PM by MS - Ryan | with 7 comments

Corruption and Bribery Compliance - Significant Measurable Metric

Bribery in your organization? Can you picture any one of your employees saying “all my competitors are doing it, so I am forced to grease the wheels just to compete”, or “there is a small chance that my (corrupt) activities will be uncovered, and even if they are uncovered I may or may not be disciplined; but, if I miss my ...
Posted: 1/25/2012 1:54:51 PM by MS - Ryan | with 7 comments

No Defence Costs from a D&O Policy

It is common in Canada that Defence Costs under a D&O policy will stop upon exhaustion of the limit of liability. There is the exception for Quebec where defence costs are outside of the limit of liability, but even Quebec risk does not guarantee unlimited defence costs. If there is any question regarding “jurisdiction” (ie. ...
Posted: 1/25/2012 1:43:24 PM by MS - Ryan | with 7 comments
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