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"Compliance Program"
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Corpus: 1990-03-17 – 2025-12-01
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EFTA00289944
Dataset 9
6p
2,464w
…governance model for the
compliance program
. This solution enables automated metrics reporting and dashboarding, auditing, risk assessment, and issues and remediation trackingof all compliance controls. In addition, Adobe implements a periodic control, process, and risk self- assessment program that allows corporate management to evaluate compliance risks and certify the operating effectiveness of compliance processes and controls. The GRC solution provides an effective mechanism for management and auditors to establish ownership and accountability over the
compliance program
and monitor its operating…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00289944.pdf
EFTA01958481
Dataset 10
2013-09-24
3p
860w
From:
Jeffrey Epstein
To:
Ada Clapp Melanie Spinella
…can be printed and submitted with the Attachment. I have attached what your client's representative may wish to use as responses to items 1-4. Item 5 addresses additional redacting you may wish for your client if you include any information other than what is on the attached draft Petition. Item 6 relates to reserving your client's right to participate in New York's Voluntary Disclosure and
Compliance program
with respect to the subject of the advisory opinion…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01958481.pdf
EFTA01958440
Dataset 10
2013-09-23
3p
725w
To:
Ada Clapp
…can be printed and submitted with the Attachment. I have attached what your client's representative may wish to use as responses to items 1-4. Item 5 addresses additional redacting you may wish for your client if you include any information other than what is on the attached draft Petition. Item 6 relates to reserving your client's right to participate in New York's Voluntary Disclosure and
Compliance program
with respect to the subject of the advisory opinion…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01958440.pdf
EFTA01382705
Dataset 10
2015-10-14
1p
638w
…credit utilization, deposit patterns and trends, industry vertical, payment history, account delinquency, financial safety and soundness, and compliance with regulations. Regulatory Compliance — We have established and maintain a regulatory
compliance program
and framework, as a second linc-of- defense, that is designed to (1) identify and establish an understanding of First Data's regulatory compliance responsibilities; (2) train owner associates; (3) achieve compliance with regulator• requirements and internal regulator• compliance policies; (4) review operations to verify responsibilities arc carried out…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01382705.pdf
EFTA01956151
Dataset 10
2013-09-24
10p
2,140w
Subject:
Re: Petition for Advisory Opinion
From:
Jeffrey Epstein
To:
Melanie Spinella[
…can be printed and submitted with the Attachment. I have attached what your client's representative may wish to use as responses to items 1-4. Item 5 addresses additional redacting you may wish for your client if you include any information other than what is on the attached draft Petition. Item 6 relates to reserving your client's right to participate in New York's Voluntary Disclosure and
Compliance program
with respect to the subject of the advisory opinion…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01956151.pdf
EFTA01958654
Dataset 10
2013-09-24
4p
1,259w
From:
Ada Clapp
To:
Jeffrey Epstein(] lliii
…can be printed and submitted with the Attachment. I have attached what your client's representative may wish to use as responses to items 1-4. Item 5 addresses additional redacting you may wish for your client if you include any information other than what is on the attached draft Petition. Item 6 relates to reserving your client's right to participate in New York's Voluntary Disclosure and
Compliance program
with respect to the subject of the advisory opinion…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01958654.pdf
EFTA01954280
Dataset 10
2013-09-23
4p
1,119w
To:
Jeffrey Epstein[leevacationegmail.com]
…can be printed and submitted with the Attachment. I have attached what your client's representative may wish to use as responses to items 1-4. Item 5 addresses additional redacting you may wish for your client if you include any information other than what is on the attached draft Petition. Item 6 relates to reserving your client's right to participate in New York's Voluntary Disclosure and
Compliance program
with respect to the subject of the advisory opinion…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01954280.pdf
EFTA00011168
Dataset 8
4p
549w
…4. I have been hired by federal and state law enforcement agencies on numerous occasions to serve as a forensic accountant/investigator for corporate monitorships and other compliance programs. For example, I was a member of the World Trade Center Integrity
Compliance Program
administered by the New York City Department of Investigation. My responsibilities included preventing and detecting wasteful or abusive practices by contractors at the World Trade Center site. My work consisted of reviewing the books and records, including…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00011168.pdf
EFTA00154570
Dataset 9
4p
549w
…4. I have been hired by federal and state law enforcement agencies on numerous occasions to serve as a forensic accountant/investigator for corporate monitorships and other compliance programs. For example, I was a member of the World Trade Center Integrity
Compliance Program
administered by the New York City Department of Investigation. My responsibilities included preventing and detecting wasteful or abusive practices by contractors at the World Trade Center site. My work consisted of reviewing the books and records, including…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00154570.pdf
EFTA00689577
Dataset 9
2013-09-24
6p
2,088w
Subject:
RE: Petition for Advisory Opinion
From:
Melanie Spinella
To:
'Jeffrey Epstein' czi
…can be printed and submitted with the Attachment. I have attached what your client's representative may wish to use as responses to items 1-4. Item 5 addresses additional redacting you may wish for your client if you include any information other than what is on the attached draft Petition. Item 6 relates to reserving your client's right to participate in New York's Voluntary Disclosure and
Compliance program
with respect to the subject of the advisory opinion…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00689577.pdf
EFTA00065761
Dataset 9
4p
549w
…4. I have been hired by federal and state law enforcement agencies on numerous occasions to serve as a forensic accountant/investigator for corporate monitorships and other compliance programs. For example, I was a member of the World Trade Center Integrity
Compliance Program
administered by the New York City Department of Investigation. My responsibilities included preventing and detecting wasteful or abusive practices by contractors at the World Trade Center site. My work consisted of reviewing the books and records, including…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00065761.pdf
EFTA00065662
Dataset 9
4p
582w
…4. I have been hired by federal and state law enforcement agencies on numerous occasions to serve as a forensic accountant/investigator for corporate monitorships and other compliance programs. For example, I was a member of the World Trade Center Integrity
Compliance Program
administered by the New York City Department of Investigation. My responsibilities included preventing and detecting wasteful or abusive practices by contractors at the World Trade Center site. My work consisted of reviewing the books and records, including…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00065662.pdf
EFTA01114626
Dataset 9
2008-07-01
4p
2,322w
…the IRS reported that this initiative government, through his attorneys, of a conspiracy had netted more than $75 million in taxes (Offshore between UBS and its US. customers to keep finan-
Compliance Program
Shows Strong Results 2003). cial account information secret from the IRS (Hil- EFTA01114627 IRS Response to PFIC 133 zenrath 2010). He hoped to become a whistleblow- (DOJ News Release #831: Former UBS Banker Sen- er and provide information to the US. which might tenced to 40 Monthsfir…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01114626.pdf
EFTA01205040
Dataset 9
6p
3,450w
…Management issues (vendor/supply requirements). U.S. Government Civilian Advisor/Subject Matter Expert (2008 to 2012) Department of Justice and State/MPRI - South Sudan, Africa Program Manager - Regulatory Compliance (1/2012 - 4/2012) • Supported a U.S. State Department International program administered by the Department of Justice in South Sudan from top to bottom including developing a
compliance program
, wrote and put in place internal program controls, supervised cross- border imports, and corrected deficiencies in pre-existing project activities including…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01205040.pdf
EFTA01377655
Dataset 10
1p
914w
…federal rules concerning lending could become applicable. Similarly, if we choose to offer Square Payroll in more jurisdictions, additional regulations, including tax rules, will apply. Although we have a
compliance program
focused on applicable laws, rules, and regulations and are continually investing more in this program, we may still be subject to fines or other penalties in one or more jurisdictions levied by federal or state or local regulators, including state Attomeys General, as well as those levied by foreign…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01377655.pdf
EFTA02462281
Dataset 11
2016-05-23
3p
900w
Subject:
fyi
From:
jeffrey E. <
[email protected]
>
To:
Shahzad Shahbaz
…2016; but on=y applicable to new accounts opened on or after May 11, 2018. What are t=e recordkeeping requirements? Recordkeeping requirements ge=erally would be the same as for current customers covered under the CIP.</=> Clarifying the AML
compliance program
requirements In addition to the new beneficial owner requirement, FinCEN is requiring that these covered institutions incorporate into their required =/span>
[email protected]
<http://ow.ly/7YKv300iNKy> , and destroy this communication and all copi=s thereof, including all attachments…
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02462281.pdf
EFTA00036705
Dataset 8
2019-04-01
28p
7,283w
Subject:
Program Summary Report - FY 2019, 3rd Quarter
From:
Assistant Director
…the management assessment process. Review findings suggest that greater emphasis is needed during operational reviews to ensure the accuracy of review findings, timeliness of reporting, and adequate modification of internal controls to prevent reoccurrence. 6 EFTA00036713 PROGRAM SUMMARY REPORT - FY 2019. 3rd QUARTER ENVIRONMENTAL AND SAFETY COMPLIANCE NUMBER OF REVIEWS: Twelve Environmental and Safety
Compliance Program
Reviews were conducted from 4/1/19 - 6/30/19, with overall ratings of six superior, five good, and one acceptable. Four repeat deficiencies…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00036705.pdf
EFTA00803448
Dataset 9
2018-03-02
7p
414w
…Asset Management LP has established policies and procedures designed to ensure that advisory activity is reasonably supervised. Mr. Fiszel and all film personnel are subject to the
compliance program
that the firm has established to comply with the Investment Advisers Act of 1940, as amended, including a Code of Ethics and Compliance Manual. Any questions regarding the
compliance program
and the policies to which Mr. Fiszel is subject should be directed to Vickramajit Sandhu, the firm's Chief Compliance Officer…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00803448.pdf
EFTA00161661
Dataset 9
2019-12-19
9p
6,617w
Subject:
FCPA Daily Digest
To:
Undisclosed recipients:;
…published even before that, said Kara Brocicmeyer of Debevoise & Plimpton LLP. Brockmeyer added that the guidance provides a lot of insight into what prosecutors are looking for. EFTA00161665 "For compliance officers at a company, it does give you a really good window into how the DOJ will evaluate your
compliance program
if you run into a problem," Brockmeyer said. Brockmeyer noted, however, that while the compliance guidance presents a picture of best practices at a large corporation, it may not…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00161661.pdf
EFTA00797609
Dataset 9
2018-06-14
4p
1,406w
…we have had an 1 EFTA00797609 opportunity to review the information, we will coordinate a telephonic interview with you, and other principals of the Adviser, to discuss the Adviser's business operations and
compliance program
. During the interview, we will also provide you with information about the National Examination Program and the New York Regional Office. Data Delivery Unless a file format is specifically requested by the exam team, please provide all requested data electronically in the file format ordinarily…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00797609.pdf
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