$5.1 Million Zurich Life Tax Settlement Highlights International Reporting Noncompliance Risks


A $5.1 million Zurich Life Group international tax settlement agreement highlights the importance for US businesses involved in international transactions of verifying and maintaining compliance with U.S. transaction reporting and other federal tax, financial and other reporting and disclosure requirements.

Zurich Life Insurance Company Ltd (Zurich Life), headquartered in Zurich, Switzerland, and Zurich International Life Limited (Zurich International Life), headquartered in the Isle of Man (collectively Zurich) will pay a $5,115,000 penalty and implement other new procedures and controls under a tax non-prosecution agreement with the Department of Justice Tax Division.

According to the terms of the non-prosecution agreement, Zurich agrees to cooperate in any related criminal or civil proceedings, to implement controls to stop misconduct involving undeclared U.S. accounts, and to pay a penalty in return for the Department’s agreement not to prosecute the insurance providers for tax-related criminal offenses.

“The Tax Division remains steadfast in its goal of ending the use of offshore banking and insurance products when used to commit tax evasion,” said Principal Deputy Assistant Attorney General Zuckerman. “This resolution with Zurich should serve as a strong message to those who use offshore bank accounts and insurance products to evade taxation that the Department of Justice is committed to stopping such fraud.”

Zurich Life was founded in 1922 and operates in Switzerland as an insurance carrier offering life insurance and investment products. As of 2016, Zurich Life had approximately $21.3 billion in assets under management and over 300,000 policies in force. Zurich International Life is based in the Isle of Man and operates as an insurance carrier offering life insurance and investment products. Zurich International Life focuses its business on the international expatriate market. As of 2016, Zurich International Life had approximately $10.6 billion in assets under management and approximately 300,000 policies in force. Zurich Life and Zurich International Life are indirectly owned subsidiaries of Zurich Insurance Group Ltd, a Swiss holding company headquartered in Zurich, Switzerland.

From Jan. 1, 2008, through June 30, 2014, Zurich issued or had certain insurance policies and accounts of U.S. taxpayer customers, who used their policies to evade U.S. taxes and reporting requirements. In particular, Zurich had approximately 420 U.S. related policies, 127 with Zurich Life and 293 with Zurich International Life, with an aggregate maximum value of approximately $102 million, for which the U.S. taxpayer customers did not provide evidence that they had declared their policies to U.S. tax authorities.

To qualify for favorable tax treatment under the U.S. tax code, insurance must meet certain minimal requirements. The policies offered by Zurich Life and Zurich International Life did not meet these requirements. The increase of the principal in these policies was therefore subject to taxation, and the policies were required to be disclosed to the Internal Revenue Service (IRS) on FinCEN Form 114 Foreign Bank Account Report, commonly referred to as an FBAR. In issuing or having undeclared U.S. related policies, Zurich knew or should have known that they were helping U.S. taxpayers conceal from the IRS ownership of undeclared assets, maintained as insurance policies or accounts.

Zurich International Life, in particular, sold insurance products to U.S. taxpayers that were “unit linked,” meaning the cash surrender value and death benefit amount were linked to the value of specified investments. With such policies, the U.S. taxpayer had a suite of specialized investment options, allowing them to access potentially higher returns by taking on the market risk associated with the policies. Some of these unit-linked policies offered a base death benefit that was nearly equivalent to the cost of the policy itself, and in some instances was fully funded by transfers from offshore bank accounts. Upon redemption, the U.S. taxpayer would receive the premium amount plus any investment earnings on the policy less a very small percentage for putative risk and fees.

Despite knowing that some of these policies, which had minimal-to-no risk mitigation function and specialized investment options, were held by U.S. taxpayers, Zurich International Life failed to act appropriately to ensure timely compliance by the policyholders with U.S. tax laws. In at least one instance, uncovered during the course of Zurich Life’s internal review, a former U.S. citizen, who pled guilty to a federal fraud offense after purchasing a Zurich International Life policy, used that insurance policy to hide substantial assets, despite owing approximately $900,000 in restitution to his victims.

Following the commencement of the Department’s Swiss Bank Program, the Zurich Group initiated a global review of the life insurance, savings and pension business sold by all of its non-U.S. operating companies to identify policies or accounts with U.S. indicia. This review prompted an extensive customer outreach to current and former customers with a possible nexus to the United States to confirm the customers’ status as U.S. taxpayers, assess their compliance with applicable U.S. tax and reporting rules, and encourage participation in an IRS voluntary disclosure program.

In July 2015, Zurich contacted the Department to inform it of the initial findings of the self-review. Prior to the self-reporting, Zurich was neither a subject nor a target of any investigation being conducted by the Tax Division. Since this self-disclosure, Zurich has conducted a thorough investigation and reported substantial findings to the Tax Division, including dozens of detailed summaries of account information and comprehensive reports for the U.S. related policies.

In addition to these efforts, the Companies have worked closely with non-U.S. regulators to ensure full disclosure to the Department. For instance, in 2016, Zurich Life applied to the Swiss Federal Department of Finance and received approval to waive Article 271 of the Swiss Criminal Code, which restricted the disclosures that Zurich Life could make to the Department, thereby facilitating Zurich Life’s production of certain information that would have otherwise been prohibited.

Part of a wave of tax prosecutions undertaken by the Trump Administration’s Justice Department, the prosecution and settlement signals the need for insurers, financial and other businesses participating international transactions to verify and maintain compliance with financial reporting and other tax, financial and other reporting, disclosure and other requirements.

About The Author

Cynthia Marcotte Stamer is a Martindale-Hubble “AV-Preeminent (Top 1%) rated practicing attorney and management consultant, health industry public policy advocate, widely published author and lecturer, recognized for her nearly 30 years’ of work with business and government clients and their leaders as a LexisNexis® Martindale-Hubbell® “LEGAL LEADER™ and “Top Rated Lawyer,” in Health Care Law and Labor and Employment Law; a D Magazine “Best Lawyers In Dallas” in the fields of “Health Care,” “Labor & Employment,” “Tax: Erisa & Employee Benefits” and “Business and Commercial Law,” a Fellow in the American Bar Foundation, the Texas Bar Foundation and the American College of Employee Benefit Counsel.

Board Certified in Labor and Employment Law by the Texas Board of Legal Specialization, Ms. Stamer serves as outside general counsel and special counsel advice, representation and other legal and operations services on a real-time “on demand,” special project and ongoing basis tailored to the needs of the domestic and multinational insurance, healthcare, energy, consulting, manufacturing and other clients on compliance, risk management and other performance and controls matters.

Best  recognized for her work on labor and employment, employee benefits and compensation, healthcare, insurance and risk management, technology and privacy and data security concerns, her experience encompasses work with management of a diverse array of clients and matters including domestic and multinational employers across many industries, health and other employee benefit plans, payroll, staffing, recruitment, technology, audit, training and coaching, consultin, and other outsourcing service providers, public and private health care providers, health and other insurers, banking and financial services, manufacturing, retail and other sales, hospitality, manufacturing, consulting, engineering bankruptcy, turnaround management restructuring and reengineering,  and other change management, technology and other vendors, nonprofit, government and others domestically and internationally.

Author of a multitude of highly-regarded works and training programs on published by BNA, the ABA and other premier legal and other industry publishers,  she also consults to and trains business and government and their leaders and speaks extensively about a wide range of general and special legal, business process and operations a and other concerns.

Beyond these involvements, Ms. Stamer also is active in the leadership of a broad range of other professional, charitable and civic organizations. Through these and other involvements, she provides hands on leadership, consulting and other support to develop and build solutions, build consensus, garner funding and other resources, manage compliance and other operations, and take other actions to identify promote tangible improvements in health care and other operations and policies.

For additional information about Ms. Stamer, see here or contact Ms. Stamer directly by e-mail here or by telephone at (469) 767-8872.

If you or someone else you know would like to receive future updates about developments on these and other concerns, please be sure that we have your current contact information including your preferred e-mail by creating or updating your profile here.
©2018.  Cynthia Marcotte Stamer. Non-exclusive right to republish granted to Solutions Law Press, Inc. All other rights reserved.

ation, audit and enforcement of policies, procedures, systems and safeguards, drafting and negotiation of business associate, chain of custody, confidentiality, and other contracting; risk assessments, audits and other risk prevention and mitigation; investigation, reporting, mitigation and resolution of known or suspected breaches, violations or other incidents; and defending investigations or other actions by plaintiffs, OCR, FTC, state attorneys’ general and other federal or state agencies, other business partners, patients and others; reporting known or suspected violations; commenting or obtaining other clarification of guidance and other regulatory affairs, training and enforcement, and a host of other related concerns.

Best  recognized for her work on labor and employment, employee benefits and compensation, healthcare, insurance and risk management, technology and privacy and data security concerns, her experience encompasses work with management of a diverse array of clients and matters including domestic and multinational employers across many industries, health and other employee benefit plans, payroll, staffing, recruitment, technology, audit, training and coaching, consultin, and other outsourcing service providers, public and private health care providers, health and other insurers, banking and financial services, manufacturing, retail and other sales, hospitality, manufacturing, consulting, engineering bankruptcy, turnaround management restructuring and reengineering,  and other change management, technology and other vendors, nonprofit, government and others domestically and internationally.

Author of a multitude of highly-regarded works and training programs on published by BNA, the ABA and other premier legal and other industry publishers,  she also consults to and trains business and government and their leaders and speaks extensively about a wide range of general and special legal, business process and operations a and other concerns.

Beyond these involvements, Ms. Stamer also is active in the leadership of a broad range of other professional, charitable and civic organizations. Through these and other involvements, she provides hands on leadership, consulting and other support to develop and build solutions, build consensus, garner funding and other resources, manage compliance and other operations, and take other actions to identify promote tangible improvements in health care and other operations and policies.

For additional information about Ms. Stamer, see here or contact Ms. Stamer directly by e-mail here or by telephone at (469) 767-8872.

If you or someone else you know would like to receive future updates about developments on these and other concerns, please be sure that we have your current contact information including your preferred e-mail by creating or updating your profile here.
©2019.  Cynthia Marcotte Stamer. Non-exclusive right to republish granted to Solutions Law Press, Inc. All other rights reserved.

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Posted in bank secrecy act, Board of Directors, CEO, CFO, Compliance, D&O, Director Liability, Employee Benefits, FinCEN, management, Officers, Officers Liability, patriot act, Performance Management, Risk Management, Uncategorized, Workforce | Leave a comment

SBA Urges FMCSA To Exempt Livestock Drivers From Hours Of Service Limits


Livestock haulers troubled by the effects of Federal Motor Carrier Safety Administration (FMCSA) rules limiting driver hours on livestock are getting support for relief from the U.S. Small Business Administration’s (SBA) Office of Advocacy.

Livestock haulers have expressed concern that the FMCSA’s application of the requirements to livestock drivers is harmful and cruel to the livestock by forcing drivers to extend the livestocks’ confinement in trailers to take mandated rest periods.

The SBS has expressed support for an application to exempt livestock drivers from the FMCSA hour restrictions.

The support was expressed in comments submitted in response to the FMCSA’s Request for Comments on Notice of Application for Exemption from Certain Provisions of Hours of Service of Drivers Rule by Livestock and Related Drivers published in the Federal Register on February 6, 2019.

The exemption application was made on behalf of drivers who transport livestock, insects, and aquatic animals with special transportation needs, and was filed by the National Cattlemen’s Beef Association, Livestock Marketing Association, American Farm Bureau Federation, American Beekeeping Federation, American Honey Producers Association and the National Aquaculture Association. The applicants request approval of a sixteen-hour on-duty period during which these drivers would be permitted to drive up to fifteen hours and would only commence after ten consecutive hours off duty. All other aspects of the current Hours of Service of Drivers rules for these drivers would remain unchanged.

Read the SBA’s Comment Letter and Fact Sheet.

About The Author

The author of this update, Cynthia Marcotte Stamer is widely recognized for her nearly 30 years’ work with health care, insurance and financial services and other public and private organizations, publications, presentations, advocacy and other work on cybersecurity and other data and privacy protection and compliance,  risk management and investigation and mitigation.

A Fellow in the American College of Employee Benefit Counsel, the American Bar Foundation and the Texas Bar Foundation; Former Chair of the RPTE Employee Benefits and Compensation Committee, a current Co-Chair of the Committee, and the former Chair of its Welfare Benefit and its Defined Compensation Plan Committees and former RPTE Joint Committee on Employee Benefits Council (JCEB) Representative, Ms. Stamer is a Martindale-Hubble “AV-Preeminent” practicing attorney and management consultant, author, public policy advocate, author and lecturer repeatedly recognized for her 30 plus years’ of work and pragmatic thought leadership, publications and training on leadership and management, and compliance concerns as among the “Top Rated Labor & Employment Lawyers in Texas,” a “Legal Leader,” a “Top Woman Lawyer” and with other awards by LexisNexis® Martindale-Hubbell®; as among the “Best Lawyers In Dallas” for her work in the field of “Labor & Employment,” “Tax: ERISA & Employee Benefits,” “Health Care” and “Business and Commercial Law” by D Magazine, in International Who’s Who of Professionals and with numerous other awards and distinctions.

Highly valued for her ability to meld her extensive legal and industry knowledge and experience with her talents as an insightful innovator and pragmatic problem solver, Ms. Stamer provides legal, operational and strategic advice, representational and coaching to organizations and their management.

Ms. Stamer also is active in the leadership of a broad range of other public policy advocacy and other professional and civic organizations and involvements. Through these and other involvements, she helps develop and build solutions, build consensus, garner funding and other resources, manage compliance and other operations, and take other actions to identify promote tangible improvements in health care and other policy and operational areas.

Before founding her current law firm, Cynthia Marcotte Stamer, P.C., Ms. Stamer practiced law as a partner with several prominent national and international law firms for more than 10 years before founding Cynthia Marcotte Stamer, P.C. to practice her unique brand of “Solutions law™” and to devote more time to the pragmatic policy and system reform, community education and innovation, and other health system improvement efforts of her PROJECT COPE: the Coalition on Patient Empowerment initiative.

About Solutions Law Press, Inc.™

Solutions Law Press, Inc.™ provides human resources and employee benefit and other business risk management, legal compliance, management effectiveness and other coaching, tools and other resources, training and education on leadership, governance, human resources, employee benefits, data security and privacy, insurance, health care and other key compliance, risk management, internal controls and operational concerns. If you find this of interest, you also be interested reviewing some of our other Solutions Law Press, Inc.™ resources at SolutionsLawPress.com.

If you or someone else you know would like to receive future updates about developments on these and other concerns, please provide your current contact information and preferences including your preferred e-mail by creating or updating your profile here.

NOTICE: These statements and materials are for general informational and purposes only. They do not establish an attorney-client relationship, are not legal advice, and do not serve as a substitute for legal advice. Readers are urged to engage competent legal counsel for consultation and representation in light of the specific facts and circumstances presented in their unique circumstance at any particular time. No comment or statement in this publication is to be construed as an admission. The author reserves the right to qualify or retract any of these statements at any time. Likewise, the content is not tailored to any particular situation and does not necessarily address all relevant issues. Because the law is rapidly evolving and rapidly evolving rules makes it highly likely that subsequent developments could impact the currency and completeness of this discussion. The presenter and the program sponsor disclaim, and have no responsibility to provide any update or otherwise notify any participant of any such change, limitation, or other condition that might affect the suitability of reliance upon these materials or information otherwise conveyed in connection with this program. Readers may not rely upon, are solely responsible for, and assume the risk and all liabilities resulting from their use of this publication.

Circular 230 Compliance. The following disclaimer is included to ensure that we comply with U.S. Treasury Department Regulations. Any statements contained herein are not intended or written by the writer to be used, and nothing contained herein can be used by you or any other person, for the purpose of (1) avoiding penalties that may be imposed under federal tax law, or (2) promoting, marketing or recommending to another party any tax-related transaction or matter addressed herein.

©2019 Cynthia Marcotte Stamer. Non-exclusive right to republish granted to Solutions  Law Press, Inc.™. For information about republication, please contact the author directly. All other rights reserved.

Posted in agriculture, trucking, Uncategorized | Leave a comment

Harris County Disability Settlement Reminder To Properly Accommodate Customer Disabilies


Businesses and government agencies should heed the reminder of the importance of providing proper accommodation from a new Justice Department settlement with Harris County, Texas announced today.

Another in a lengthy series of disability accommodation enforcement settlements, the agreement resolves a Justice Department lawsuit alleging that Harris County violated Title II of the Americans with Disabilities Act (ADA) by failing to provide an accessible voting program to voters with disabilities, including accessible polling places.

Harris County’s voting program—the third largest in the country—includes over 750 polling places. The Justice Department’s complaint alleges that many polling places in Harris County have architectural barriers—such as steep ramps, gaps in sidewalks and walkways, and locked gates along the route barring pedestrian access—that make them inaccessible to voters with mobility impairments or voters who are blind or visually impaired.

Under the agreement, Harris County will create and implement policies, practices, and procedures to bring its voting program into compliance with the ADA, including creating an effective system for selecting accessible facilities for polling places, surveying polling place facilities for accessibility barriers, procuring and implementing temporary accessibility remedies during elections, providing effective curbside voting, and hiring Subject Matter Experts to provide technical assistance and training to the County as well as provide reports to the parties on the County’s compliance with the agreement.

The Harris County settlement is the latest of many enforcement actions including many with substantial recoveries of damages and/or penalties.

About The Author

The author of this update, Cynthia Marcotte Stamer is widely recognized for her nearly 30 years’ work with health care, insurance and financial services and other public and private organizations, publications, presentations, advocacy and other work on cybersecurity and other data and privacy protection and compliance,  risk management and investigation and mitigation.

A Fellow in the American College of Employee Benefit Counsel, the American Bar Foundation and the Texas Bar Foundation; Former Chair of the RPTE Employee Benefits and Compensation Committee, a current Co-Chair of the Committee, and the former Chair of its Welfare Benefit and its Defined Compensation Plan Committees and former RPTE Joint Committee on Employee Benefits Council (JCEB) Representative, Ms. Stamer is a Martindale-Hubble “AV-Preeminent” practicing attorney and management consultant, author, public policy advocate, author and lecturer repeatedly recognized for her 30 plus years’ of work and pragmatic thought leadership, publications and training on leadership and management, and compliance concerns as among the “Top Rated Labor & Employment Lawyers in Texas,” a “Legal Leader,” a “Top Woman Lawyer” and with other awards by LexisNexis® Martindale-Hubbell®; as among the “Best Lawyers In Dallas” for her work in the field of “Labor & Employment,” “Tax: ERISA & Employee Benefits,” “Health Care” and “Business and Commercial Law” by D Magazine, in International Who’s Who of Professionals and with numerous other awards and distinctions.

Highly valued for her ability to meld her extensive legal and industry knowledge and experience with her talents as an insightful innovator and pragmatic problem solver, Ms. Stamer provides legal, operational and strategic advice, representational and coaching to organizations and their management.

Ms. Stamer also is active in the leadership of a broad range of other public policy advocacy and other professional and civic organizations and involvements. Through these and other involvements, she helps develop and build solutions, build consensus, garner funding and other resources, manage compliance and other operations, and take other actions to identify promote tangible improvements in health care and other policy and operational areas.

Before founding her current law firm, Cynthia Marcotte Stamer, P.C., Ms. Stamer practiced law as a partner with several prominent national and international law firms for more than 10 years before founding Cynthia Marcotte Stamer, P.C. to practice her unique brand of “Solutions law™” and to devote more time to the pragmatic policy and system reform, community education and innovation, and other health system improvement efforts of her PROJECT COPE: the Coalition on Patient Empowerment initiative.

About Solutions Law Press, Inc.™

Solutions Law Press, Inc.™ provides human resources and employee benefit and other business risk management, legal compliance, management effectiveness and other coaching, tools and other resources, training and education on leadership, governance, human resources, employee benefits, data security and privacy, insurance, health care and other key compliance, risk management, internal controls and operational concerns. If you find this of interest, you also be interested reviewing some of our other Solutions Law Press, Inc.™ resources at SolutionsLawPress.com.

If you or someone else you know would like to receive future updates about developments on these and other concerns, please provide your current contact information and preferences including your preferred e-mail by creating or updating your profile here.

NOTICE: These statements and materials are for general informational and purposes only. They do not establish an attorney-client relationship, are not legal advice, and do not serve as a substitute for legal advice. Readers are urged to engage competent legal counsel for consultation and representation in light of the specific facts and circumstances presented in their unique circumstance at any particular time. No comment or statement in this publication is to be construed as an admission. The author reserves the right to qualify or retract any of these statements at any time. Likewise, the content is not tailored to any particular situation and does not necessarily address all relevant issues. Because the law is rapidly evolving and rapidly evolving rules makes it highly likely that subsequent developments could impact the currency and completeness of this discussion. The presenter and the program sponsor disclaim, and have no responsibility to provide any update or otherwise notify any participant of any such change, limitation, or other condition that might affect the suitability of reliance upon these materials or information otherwise conveyed in connection with this program. Readers may not rely upon, are solely responsible for, and assume the risk and all liabilities resulting from their use of this publication.

Circular 230 Compliance. The following disclaimer is included to ensure that we comply with U.S. Treasury Department Regulations. Any statements contained herein are not intended or written by the writer to be used, and nothing contained herein can be used by you or any other person, for the purpose of (1) avoiding penalties that may be imposed under federal tax law, or (2) promoting, marketing or recommending to another party any tax-related transaction or matter addressed herein.

©2019 Cynthia Marcotte Stamer. Non-exclusive right to republish granted to Solutions  Law Press, Inc.™. For information about republication, please contact the author directly. All other rights reserved.

Posted in Uncategorized | Leave a comment

Appeals Court Rules Corporation Can’t Deduct Excise Tax Not Paid As Tax Deduction


Federal corporate taxpayers may not deduct as a cost of goods sold expense an excise tax expense that was never actually incurred or paid according the Federal Circuit Court of Appeals just-released ruling in Sunoco, Inc. v. United States, No. 2017-1402 (November 1, 2018).

In Sonoco, Inc.,  the Federal Circuit Court of Appeals considered the approximately $1 billion deduction in alcohol fuel mixture credits claimed by  Sunoco, Inc., a petroleum and petrochemical company, claimed on its federal excise tax returns to reduce its federal fuel excise tax liability by the same amount. By including the $1 billion in excise tax expenses in its cost of goods sold, Sunoco, Inc. sought to reduce its federal corporate income taxes with an excise tax expense that was never paid. The Federal Circuit held that the plain language of the Internal Revenue Code precluded Sunoco, Inc.’s attempt to obtain a $300 million dollar “windfall” reduction in tax. The court also stated, “We have already established that Congress does not generally allow taxpayers to receive a tax benefit twice.”

The Federal Circuit Court of Appeals issued a precedential opinion today affirming the Court of Federal Claims decision that federal corporate taxpayers may not deduct as a cost of goods sold expense an excise tax expense that was never actually incurred or paid,

About The Author

The author of this update, Cynthia Marcotte Stamer is widely recognized for her nearly 30 years’ work with health care, insurance and financial services and other public and private organizations, publications, presentations, advocacy and other work on cybersecurity and other data and privacy protection and compliance,  risk management and investigation and mitigation.

A Fellow in the American College of Employee Benefit Counsel, the American Bar Foundation and the Texas Bar Foundation; Former Chair of the RPTE Employee Benefits and Compensation Committee, a current Co-Chair of the Committee, and the former Chair of its Welfare Benefit and its Defined Compensation Plan Committees and former RPTE Joint Committee on Employee Benefits Council (JCEB) Representative, Ms. Stamer is a Martindale-Hubble “AV-Preeminent” practicing attorney and management consultant, author, public policy advocate, author and lecturer repeatedly recognized for her 30 plus years’ of work and pragmatic thought leadership, publications and training on leadership and management, and compliance concerns as among the “Top Rated Labor & Employment Lawyers in Texas,” a “Legal Leader,” a “Top Woman Lawyer” and with other awards by LexisNexis® Martindale-Hubbell®; as among the “Best Lawyers In Dallas” for her work in the field of “Labor & Employment,” “Tax: ERISA & Employee Benefits,” “Health Care” and “Business and Commercial Law” by D Magazine, in International Who’s Who of Professionals and with numerous other awards and distinctions.

Highly valued for her ability to meld her extensive legal and industry knowledge and experience with her talents as an insightful innovator and pragmatic problem solver, Ms. Stamer provides legal, operational and strategic advice, representational and coaching to organizations and their management.

Ms. Stamer also is active in the leadership of a broad range of other public policy advocacy and other professional and civic organizations and involvements. Through these and other involvements, she helps develop and build solutions, build consensus, garner funding and other resources, manage compliance and other operations, and take other actions to identify promote tangible improvements in health care and other policy and operational areas.

Before founding her current law firm, Cynthia Marcotte Stamer, P.C., Ms. Stamer practiced law as a partner with several prominent national and international law firms for more than 10 years before founding Cynthia Marcotte Stamer, P.C. to practice her unique brand of “Solutions law™” and to devote more time to the pragmatic policy and system reform, community education and innovation, and other health system improvement efforts of her PROJECT COPE: the Coalition on Patient Empowerment initiative.

About Solutions Law Press, Inc.™

Solutions Law Press, Inc.™ provides human resources and employee benefit and other business risk management, legal compliance, management effectiveness and other coaching, tools and other resources, training and education on leadership, governance, human resources, employee benefits, data security and privacy, insurance, health care and other key compliance, risk management, internal controls and operational concerns. If you find this of interest, you also be interested reviewing some of our other Solutions Law Press, Inc.™ resources at SolutionsLawPress.com.

If you or someone else you know would like to receive future updates about developments on these and other concerns, please provide your current contact information and preferences including your preferred e-mail by creating or updating your profile here.

NOTICE: These statements and materials are for general informational and purposes only. They do not establish an attorney-client relationship, are not legal advice, and do not serve as a substitute for legal advice. Readers are urged to engage competent legal counsel for consultation and representation in light of the specific facts and circumstances presented in their unique circumstance at any particular time. No comment or statement in this publication is to be construed as an admission. The author reserves the right to qualify or retract any of these statements at any time. Likewise, the content is not tailored to any particular situation and does not necessarily address all relevant issues. Because the law is rapidly evolving and rapidly evolving rules makes it highly likely that subsequent developments could impact the currency and completeness of this discussion. The presenter and the program sponsor disclaim, and have no responsibility to provide any update or otherwise notify any participant of any such change, limitation, or other condition that might affect the suitability of reliance upon these materials or information otherwise conveyed in connection with this program. Readers may not rely upon, are solely responsible for, and assume the risk and all liabilities resulting from their use of this publication.

Circular 230 Compliance. The following disclaimer is included to ensure that we comply with U.S. Treasury Department Regulations. Any statements contained herein are not intended or written by the writer to be used, and nothing contained herein can be used by you or any other person, for the purpose of (1) avoiding penalties that may be imposed under federal tax law, or (2) promoting, marketing or recommending to another party any tax-related transaction or matter addressed herein.

©2018 Cynthia Marcotte Stamer. Non-exclusive right to republish granted to Solutions  Law Press, Inc.™. For information about republication, please contact the author directly. All other rights reserved.

Posted in Board of Directors, CEO, CFO, Compliance, Cyber, data breach, Fraud, Leadership, Privacy, Tax, Uncategorized | Leave a comment

Protect Your Website & Website Data Against Cybersecurity Threats


The United States Computer Emergency Readiness Team of the Department of Homeland Security (US-CERT) is urging all organizations and individuals operating websites to confirm the adequacy of the website security measures and practices of their organizations’ websites to reduce their organizations to the financial, operational and reputational disruptions and risks created by the increasingly persistent ransomware and other hacking, data breach and cybersecurity threats.

Website security refers to the protection of personal and organizational public-facing websites from cyberattacks.

Cyberattacks against public-facing websites—regardless of size—are common. An attack to your website could

  • Cause defacement,
  • Cause a denial-of-service (DoS) condition,
  • Enable the attacker to obtain sensitive information, or
  • Enable the attacker to take control of the affected website.

Depending on the content and functionality of the particular website, organization and personal websites that fall victim to defacement or DoS may experience financial loss, legal liability, operational disruptions, reputational damage and other material costs and disruptions due to eroded user trust or a decrease in website visitors.

Liability can arise from a host of sources.  For instance, a cyberattack that causes a data breach places your company’s intellectual property and users’ personally identifiable information (PII) at risk of theft.  Businesses whose websites collect or receive credit, credit card, or other personal financial information generally are required to monitor and maintain the security of such information under the federal Fair and Accurate Credit Transactions Act (FACTA) and various other federal and state data security, identity theft and other identity theft, electronic crimes and data security laws.  Meanwhile, the Internal Revenue Code and various other federal or state tax and other laws obligate employers, tax advisors and tax prepares and others collecting or maintaining  tax information to take appropriate steps to safeguard tax information they create or maintain electronically against misuse. Beyond these and other commonly applicable data and cybersecurity requirements, certain industries also often face industry specific mandates concerning the security of websites and other electronic systems containing sensitive information.  For instance, the Privacy, Security and Breach Notification rules of the Health Insurance Portability and Accountability Act (HIPAA)  and most states impose detailed requirements for maintaining the security of websites and other operating systems containing electronic protected health information (ePHI) on health care providers, health plans or health insurers,  health care clearing houses and their business associates including affirmative requirements to monitor data and systems for threats or occurrences of unauthorized access and to take corrective action and provide specific notifications within specific timeframes.  Moreover, virtually all organizations maintaining or using websites also are subject to specific requirements to provide notifications about privacy and data security practices under various laws, as well as various contractual obligations concerning the protection of website data. Beyond the liabilities and sanctions that various applicable laws may impose for violations of their applicable requirements, noncompliance with these and other specific legal website and data security responsibilities, breaches of contractual, statutory or regulatory duties, misrepresentations about the adequacy of safeguards, and common law privacy theories also can create substantial damage exposure.  Even where this is not the case, however, organizations websites or website data are breached typically incur substantial operational expense, disruption, public, investor relations and other reputational harm, and other damages as a result of the security breaches.  Consequently, all organizations should tailor and monitor their website security to ensure these requirements are met as well as following other website security best practices.

  • What security threats are associated with websites?

US-CERT says cyber criminals may attack websites because of financial incentives such as the theft and sale of intellectual property and PII, ransomware payouts, and cryptocurrency mining (see Defending Against Illicit Cryptocurrency Mining Activity). Cyber criminals may also be motivated to attack websites for ideological reasons, e.g., to gain publicity and notoriety for a terrorist organization through defacing a government website.

Possible cyberattacks against your website include those commonly reported in the media, such as website defacement and DoS—which make the information services provided by the website unavailable for users (see Understanding Denial-of-Service Attacks). An even more severe website attack scenario may result in the compromise of customer data (e.g., PII). These threats affect all aspects of security—confidentiality, integrity, and availability—and can gravely damage the reputation of the website and its owner.

A more subtle attack—one that may not be immediately evident to the website’s owner or user—occurs when an attacker pivots from a compromised web server to the website owner’s corporate network, which contains an abundance of sensitive information that may be at risk of exposure, modification, or destruction. Once an attacker uses a compromised website to enter a corporate network, other assets may be available to the attacker, including user credentials, PII, administrative information, and technical vulnerabilities. Additionally, by compromising the website platform, an attacker may be able to repurpose the website infrastructure as a platform from which they can launch attacks against other systems.

  • How to improve cybersecurity protection against website attacks?

Organizations covered by affirmative federal or state mandates such as HIPAA, FACTA, the Internal Revenue Code or other federal or state data security, data breach, identity theft or other requirements should ensure that their website security at all times fulfills all of these applicable requirements and maintain clear documentation of these efforts.  Beyond meeting these specific legal mandates, US-CERT recommends that organizations and individuals act to protect their websites by applying the following the best practices to their web servers:

  • Implement the principle of least privilege. Ensure that all users have the least amount of privilege necessary on the web server (including interactive end users and service accounts).
  • Use multifactor authentication. Implement multifactor authentication for user logins to web applications and the underlying website infrastructure.
  • Change default vendor usernames and passwords. Default vendor credentials are not secure—they are usually readily available on the internet. Changing default usernames and passwords will prevent an attack that leverages default credentials.
  • Disable unnecessary accounts. Disable accounts that are no longer necessary, such as guest accounts or individual user accounts that are no longer in use.
  • Use security checklists. Audit and harden configurations based on security checklists specific to each application (e.g., Apache, MySQL) on the system.
  • Use application whitelisting. Use application whitelisting and disable modules or features that provide capabilities that are not necessary for business needs.
  • Use network segmentation and segregation. Network segmentation and segregation makes it more difficult for attackers to move laterally within connected networks. For example, placing the web server in a properly configured demilitarized zone (DMZ) limits the type of network traffic permitted between systems in the DMZ and systems in the internal corporate network.
  • Know where your assets are. You must know where your assets are in order to protect them. For example, if you have data that does not need to be on the web server, remove it to protect it from public access.
  • Protect the assets on the web server. Protect assets on the web server with multiple layers of defense (e.g., limited user access, encryption at rest).
  • Practice healthy cyber hygiene.
    • Patch systems at all levels—from web applications and backend database applications, to operating systems and hypervisors.
    • Perform routine backups, and test disaster recovery scenarios.
    • Configure extended logging and send the logs to a centralized log server.

Beyond these steps, US-CERT also suggests the following steps:

  • Sanitize all user input. Sanitize user input, such as special characters and null characters, at both the client end and the server end. Sanitizing user input is especially critical when it is incorporated into scripts or structured query language statements.
  • Increase resource availability. Configure your website caching to optimize resource availability. Optimizing your website’s resource availability increases the chance that your website will withstand unexpectedly high amounts of traffic during DoS attacks.
  • Implement cross-site scripting (XSS) and cross-site request forgery (XSRF) protections. Protect your website system, as well as visitors to your website, by implementing XSS and XSRF protections.
  • Implement a Content Security Policy (CSP). Website owners should also consider implementing a CSP. Implementing a CSP lessens the chances of an attacker successfully loading and running malicious JavaScript on the end user machine.
  • Audit third-party code. Audit third-party services (e.g., ads, analytics) to validate that no unexpected code is being delivered to the end user. Website owners should weigh the pros and cons of vetting the third-party code and hosting it on the web server (as opposed to loading the code from the third party).
  • Implement hypertext transfer protocol secure (HTTPS) and HTTP strict transport security (HSTS). Website visitors expect their privacy to be protected. To ensure communications between the website and user are encrypted, always enforce the use of HTTPS, and enforce the use of HSTS where possible. For further information and guidance, see the U.S. Chief Information Officer (CIO) and the Federal CIO Council’s webpage on the HTTPS-Only Standard.
  • Implement additional security measures. Additional measures include
    • Running static and dynamic security scans against the website code and system,
    • Deploying web application firewalls,
    • Leveraging content delivery networks to protect against malicious web traffic, and
    • Providing load balancing and resilience against high amounts of traffic.

For additional guidance, US-CERT recomends visiting  the Open Web Application Security Project Top 10 Cheat Sheet on common critical risks to web applications, the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-44: Guidelines on Securing Public Web Servers, and NIST SP 800-95: Guide to Secure Web Services. Subscribe to NCCIC Current Activities to stay current on the latest website technology vulnerabilities.

About The Author

The author of this update, Cynthia Marcotte Stamer is widely recognized for her nearly 30 years’ work with health care, insurance and financial services and other public and private organizations, publications, presentations, advocacy and other work on cybersecurity and other data and privacy protection and compliance,  risk management and investigation and mitigation.

A Fellow in the American College of Employee Benefit Counsel, the American Bar Foundation and the Texas Bar Foundation; Former Chair of the RPTE Employee Benefits and Compensation Committee, a current Co-Chair of the Committee, and the former Chair of its Welfare Benefit and its Defined Compensation Plan Committees and former RPTE Joint Committee on Employee Benefits Council (JCEB) Representative, Ms. Stamer is a Martindale-Hubble “AV-Preeminent” practicing attorney and management consultant, author, public policy advocate, author and lecturer repeatedly recognized for her 30 plus years’ of work and pragmatic thought leadership, publications and training on leadership and management, and compliance concerns as among the “Top Rated Labor & Employment Lawyers in Texas,” a “Legal Leader,” a “Top Woman Lawyer” and with other awards by LexisNexis® Martindale-Hubbell®; as among the “Best Lawyers In Dallas” for her work in the field of “Labor & Employment,” “Tax: ERISA & Employee Benefits,” “Health Care” and “Business and Commercial Law” by D Magazine, in International Who’s Who of Professionals and with numerous other awards and distinctions.

Highly valued for her ability to meld her extensive legal and industry knowledge and experience with her talents as an insightful innovator and pragmatic problem solver, Ms. Stamer provides legal, operational and strategic advice, representational and coaching to organizations and their management.

Ms. Stamer also is active in the leadership of a broad range of other public policy advocacy and other professional and civic organizations and involvements. Through these and other involvements, she helps develop and build solutions, build consensus, garner funding and other resources, manage compliance and other operations, and take other actions to identify promote tangible improvements in health care and other policy and operational areas.

Before founding her current law firm, Cynthia Marcotte Stamer, P.C., Ms. Stamer practiced law as a partner with several prominent national and international law firms for more than 10 years before founding Cynthia Marcotte Stamer, P.C. to practice her unique brand of “Solutions law™” and to devote more time to the pragmatic policy and system reform, community education and innovation, and other health system improvement efforts of her PROJECT COPE: the Coalition on Patient Empowerment initiative.

About Solutions Law Press, Inc.™

Solutions Law Press, Inc.™ provides human resources and employee benefit and other business risk management, legal compliance, management effectiveness and other coaching, tools and other resources, training and education on leadership, governance, human resources, employee benefits, data security and privacy, insurance, health care and other key compliance, risk management, internal controls and operational concerns. If you find this of interest, you also be interested reviewing some of our other Solutions Law Press, Inc.™ resources at SolutionsLawPress.com.

If you or someone else you know would like to receive future updates about developments on these and other concerns, please provide your current contact information and preferences including your preferred e-mail by creating or updating your profile here.

NOTICE: These statements and materials are for general informational and purposes only. They do not establish an attorney-client relationship, are not legal advice, and do not serve as a substitute for legal advice. Readers are urged to engage competent legal counsel for consultation and representation in light of the specific facts and circumstances presented in their unique circumstance at any particular time. No comment or statement in this publication is to be construed as an admission. The author reserves the right to qualify or retract any of these statements at any time. Likewise, the content is not tailored to any particular situation and does not necessarily address all relevant issues. Because the law is rapidly evolving and rapidly evolving rules makes it highly likely that subsequent developments could impact the currency and completeness of this discussion. The presenter and the program sponsor disclaim, and have no responsibility to provide any update or otherwise notify any participant of any such change, limitation, or other condition that might affect the suitability of reliance upon these materials or information otherwise conveyed in connection with this program. Readers may not rely upon, are solely responsible for, and assume the risk and all liabilities resulting from their use of this publication.

Circular 230 Compliance. The following disclaimer is included to ensure that we comply with U.S. Treasury Department Regulations. Any statements contained herein are not intended or written by the writer to be used, and nothing contained herein can be used by you or any other person, for the purpose of (1) avoiding penalties that may be imposed under federal tax law, or (2) promoting, marketing or recommending to another party any tax-related transaction or matter addressed herein.

©2018 Cynthia Marcotte Stamer. Non-exclusive right to republish granted to Solutions  Law Press, Inc.™. For information about republication, please contact the author directly. All other rights reserved.

Posted in Board of Directors, CEO, CFO, Compliance, Cyber, data breach, Fraud, Leadership, Privacy, Uncategorized | Leave a comment

12/17 Deadline to Comment on EPA’s Proposed Improvements to Methane Rule Governing New Oil and Gas Sources


December 17 is the deadline to comment on proposed reconsideration amendments to the Environmental Protection Agency’s (EPAs) new source performance standards (NSPS) affecting emissions of volatile organic compounds (VOCs) and methane the EPA proposed October 15, 2018.  The changes are supported by the Trump Administration and many energy and other business leaders as easing burdensome regulations that many US business leaders see as placing US businesses at a disadvantage in the world markets.

The EPA received petitions for reconsideration of the 2016 NSPS OOOOa. In 2017, the EPA granted reconsideration on the fugitive emissions requirements, well site pneumatic pump standards, and the requirements for certification of closed vent systems by a professional engineer based on specific objections to these requirements. This action proposes amendments and clarifications as a result of reconsideration of these issues. The proposed amendments also address other issues raised for reconsideration and make technical corrections and amendments to further clarify the rule.

Comments on this proposed rule are due on December 17, 2018.

  • Find information about the rule, including the proposal, here.
  • Read the fact sheet here.
  • Submit electronic comments here.
  • Advocacy contact: Kevin Bromberg at 202-205-6964.

About the Author

Cynthia Marcotte Stamer is a Martindale-Hubble “AV-Preeminent (Top 1%) rated practicing attorney and management consultant, health industry public policy advocate, widely published author and lecturer, recognized for her nearly 30 years’ of work with business and government clients and their leaders as a LexisNexis® Martindale-Hubbell® “LEGAL LEADER™ and “Top Rated Lawyer,” in Health Care Law and Labor and Employment Law; a D Magazine “Best Lawyers In Dallas” in the fields of “Health Care,” “Labor & Employment,” “Tax: Erisa & Employee Benefits” and “Business and Commercial Law,” a Fellow in the American Bar Foundation, the Texas Bar Foundation and the American College of Employee Benefit Counsel.

Board Certified in Labor and Employment Law by the Texas Board of Legal Specialization, Ms. Stamer serves as outside general counsel and special counsel advice, representation and other legal and operations services on a real-time “on demand,” special project and ongoing basis tailored to the needs of the client.  hroughout her career with health care providers, health plans, health care clearinghouses, their business associates, employers and other plan sponsors, banks, insurers and other financial institutions, and others on trade secret confidentiality, privacy, data security and other risk management and compliance including design, establishment, documentation, implementation, audit and enforcement of policies, procedures, systems and safeguards, drafting and negotiation of business associate, chain of custody, confidentiality, and other contracting; risk assessments, audits and other risk prevention and mitigation; investigation, reporting, mitigation and resolution of known or suspected breaches, violations or other incidents; and defending investigations or other actions by plaintiffs, OCR, FTC, state attorneys’ general and other federal or state agencies, other business partners, patients and others; reporting known or suspected violations; commenting or obtaining other clarification of guidance and other regulatory affairs, training and enforcement, and a host of other related concerns.

Best  recognized for her work on labor and employment, employee benefits and compensation, healthcare, insurance and risk management, technology and privacy and data security concerns, her experience encompasses work with management of a diverse array of clients and matters including domestic and multinational employers across many industries, health and other employee benefit plans, payroll, staffing, recruitment, technology, audit, training and coaching, consultin, and other outsourcing service providers, public and private health care providers, health and other insurers, banking and financial services, manufacturing, retail and other sales, hospitality, manufacturing, consulting, engineering bankruptcy, turnaround management restructuring and reengineering,  and other change management, technology and other vendors, nonprofit, government and others domestically and internationally.

Author of a multitude of highly-regarded works and training programs on published by BNA, the ABA and other premier legal and other industry publishers,  she also consults to and trains business and government and their leaders and speaks extensively about a wide range of general and special legal, business process and operations a and other concerns.

Beyond these involvements, Ms. Stamer also is active in the leadership of a broad range of other professional, charitable and civic organizations. Through these and other involvements, she provides hands on leadership, consulting and other support to develop and build solutions, build consensus, garner funding and other resources, manage compliance and other operations, and take other actions to identify promote tangible improvements in health care and other operations and policies.

For additional information about Ms. Stamer, see here or contact Ms. Stamer directly by e-mail here or by telephone at (469) 767-8872.  If you or someone else you know would like to receive future updates about developments on these and other concerns, please be sure that we have your current contact information including your preferred e-mail by creating or updating your profile here.   ©2018 Cynthia Marcotte Stamer. Non-exclusive right to republish granted to Solutions Law Press, Inc. All other rights reserved.

Posted in bank secrecy act, Board of Directors, CEO, CFO, Compliance, Director Liability, FinCEN, management, Officers, Officers Liability, patriot act, Uncategorized | Leave a comment

11/27 Deadline To Comment On Proposed SBA Express Loan Programs and Affiliation Programs Rule Changes


November 27, 2018 is the deadline to submit support or other comments on proposed changes to the U.S. Small Business Administration (SBA) Express Loan Programs; Affiliation Programs published last week.

The proposed rule changes published September 28, 2018 will amend various regulations governing its business loan programs, including the SBA Express and Export Express Loan Programs and the Microloan and Development Company (504) loan programs.

Among other things, the proposed rule would:

  • Incorporate into the regulations governing the 7(a) Loan Program the requirements specifically applicable to the SBA Express and Export Express Loan Programs;
  • Add a new regulation to require certain owners of the small business Applicant to inject excess liquid assets into the business to reduce the amount of SBA-guaranteed funds that otherwise would be needed;
  • Revise the regulations concerning allowable fees for the 7(a) Loan Program to limit the fees payable by the small business Applicant and to clarify what SBA considers reasonable with respect to such fees;
  • Amend the regulation that explains the Agency’s policy governing SBA-guaranteed loans to qualified employee trusts to require that all such applications be processed under non-delegated procedures;
  • Incorporate a change to implement SBA’s long-standing policy regarding the responsibility of a Lender for the contingent liabilities (including repairs and denials) for Lenders purchasing 7(a) loans from the Federal Deposit Insurance Corporation (FDIC) (as receiver, conservator, or other liquidator of a failed insured depository institution), whether such loans are acquired through a loan sale where SBA has not already purchased the guaranty or through a whole bank transfer;
  • Revise the regulations governing the use of microloan grant funds by Microloan Intermediaries and extend the maximum maturity of a microloan;
  • Modify the affiliation principles applicable to SBA’s financial assistance programs to include additional circumstances when a small business Applicant will be deemed to be affiliated with another entity for purposes of determining the small business Applicant’s size;
  • Amend the regulation identifying when the size status of an Applicant for financial assistance is determined with respect to applications under the SBA Express and Export Express Loan Programs; and
  • Make technical corrections to the regulation identifying prohibited fees in the 7(a) Loan Program and the regulation discussing the application for the Accredited Lenders Program (ALP) in the 504 Loan Program, as well as conforming amendments to two existing regulations for consistency with the proposed regulations governing SBA Express and Export Express, and a conforming amendment to one existing regulation for consistency with the proposed changes to the allowable fees that may be charged in connection with a 7(a) loan.

Comments must be received on or before November 27, 2018 through the Federal eRulemaking Portal, via mail or hand delivery.  For more information or assistance, contact the author.

About the Author

Cynthia Marcotte Stamer is a Martindale-Hubble “AV-Preeminent (Top 1%) rated practicing attorney and management consultant, health industry public policy advocate, widely published author and lecturer, recognized for her nearly 30 years’ of work with business and government clients and their leaders as a LexisNexis® Martindale-Hubbell® “LEGAL LEADER™ and “Top Rated Lawyer,” in Health Care Law and Labor and Employment Law; a D Magazine “Best Lawyers In Dallas” in the fields of “Health Care,” “Labor & Employment,” “Tax: Erisa & Employee Benefits” and “Business and Commercial Law,” a Fellow in the American Bar Foundation, the Texas Bar Foundation and the American College of Employee Benefit Counsel.

Board Certified in Labor and Employment Law by the Texas Board of Legal Specialization, Ms. Stamer serves as outside general counsel and special counsel advice, representation and other legal and operations services on a real-time “on demand,” special project and ongoing basis tailored to the needs of the client.  hroughout her career with health care providers, health plans, health care clearinghouses, their business associates, employers and other plan sponsors, banks, insurers and other financial institutions, and others on trade secret confidentiality, privacy, data security and other risk management and compliance including design, establishment, documentation, implementation, audit and enforcement of policies, procedures, systems and safeguards, drafting and negotiation of business associate, chain of custody, confidentiality, and other contracting; risk assessments, audits and other risk prevention and mitigation; investigation, reporting, mitigation and resolution of known or suspected breaches, violations or other incidents; and defending investigations or other actions by plaintiffs, OCR, FTC, state attorneys’ general and other federal or state agencies, other business partners, patients and others; reporting known or suspected violations; commenting or obtaining other clarification of guidance and other regulatory affairs, training and enforcement, and a host of other related concerns.

Best  recognized for her work on labor and employment, employee benefits and compensation, healthcare, insurance and risk management, technology and privacy and data security concerns, her experience encompasses work with management of a diverse array of clients and matters including domestic and multinational employers across many industries, health and other employee benefit plans, payroll, staffing, recruitment, technology, audit, training and coaching, consultin, and other outsourcing service providers, public and private health care providers, health and other insurers, banking and financial services, manufacturing, retail and other sales, hospitality, manufacturing, consulting, engineering bankruptcy, turnaround management restructuring and reengineering,  and other change management, technology and other vendors, nonprofit, government and others domestically and internationally.

Author of a multitude of highly-regarded works and training programs on published by BNA, the ABA and other premier legal and other industry publishers,  she also consults to and trains business and government and their leaders and speaks extensively about a wide range of general and special legal, business process and operations a and other concerns.

Beyond these involvements, Ms. Stamer also is active in the leadership of a broad range of other professional, charitable and civic organizations. Through these and other involvements, she provides hands on leadership, consulting and other support to develop and build solutions, build consensus, garner funding and other resources, manage compliance and other operations, and take other actions to identify promote tangible improvements in health care and other operations and policies.

For additional information about Ms. Stamer, see here or contact Ms. Stamer directly by e-mail here or by telephone at (469) 767-8872.  If you or someone else you know would like to receive future updates about developments on these and other concerns, please be sure that we have your current contact information including your preferred e-mail by creating or updating your profile here.   ©2018 Cynthia Marcotte Stamer. Non-exclusive right to republish granted to Solutions Law Press, Inc. All other rights reserved.

Posted in bank secrecy act, Board of Directors, CEO, CFO, Compliance, Director Liability, FinCEN, management, Officers, Officers Liability, patriot act, Uncategorized | Leave a comment