compliance

In May 2018, a Deutsche Bank compliance officer noticed payments from Epstein to the Russian bank accounts of women with Eastern European surnames.

Only then did the backbone scale: We went from server closets wedged next to the mop sink to data centers and cloud regions, from lone system administrators to fulfillment networks, cybersecurity and compliance.

The firm also cautions nonprofits to tighten their compliance practices by seeking legal advice on potential risks, vetting partners and funders, and adding oversight where needed.

The focus is on monitoring and the imposition of measures that return a club to compliance for any breach.

“Ventura County was one of the counties where unannounced audits occurred, and those findings reinforced the need for stronger compliance,” Nasarenko said.