MyComplianceOffice Blog

The Financial Conduct Authority (FCA) has published this week a decision note about the CEO of Worldspreads (WSL), Conor Foley. The FCA is seeking to fine Mr Foley for market abuse and ban him from working on regulated activities. The decision note was published on July 7 but follow an investigation that started in 2012. The FCA accuses the executive of committing market abuse by disseminating false information and manipulate transactions.

The US Department of Justice (DOJ) recently published an updated version of its guidance on the Evaluation of Corporate Compliance Programs.

The guidance provides direction regarding corporate compliance best practices and addresses the three fundamental questions that should be used to evaluate a corporate compliance program.

When a company makes the decision to implement compliance software, the steps they take at the very beginning of the process are likely to determine whether they end up with the right technology. Procurement’s strategic sourcing process provides an effective methodology for identifying, comparing, and selecting a vendor, but it cannot be effective without a solid foundation of objectively set specifications and requirements. Without the right process and inputs, regret is just around the corner.

One of the top reasons enterprise decision-makers give for not wanting to work with procurement is the time required to complete the sourcing and vendor selection process. Why is it necessary to have a long, formal evaluation effort when you already know which compliance software provider you want to work with? Can’t procurement just help push through the contract? The frustration with procurement delays is especially pronounced in an era when eCommerce makes nearly any good or service available to us at home within 48 hours, and when SaaS compliance technology can be ‘turned on’ instantly.

The Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) recently published the Risk Alert Observations from Examinations of Investment Advisers Managing Private Funds. 

The Risk Alert covers three general areas of deficiencies that the OCIE has identified in examinations of private fund advisers: conflicts of interest, fees and expenses, and policies and procedures relating to material non-public information (MNPI). The alert outlines concerns and compliance issues observed during examinations of registered investment advisers that manage private equity funds or hedge funds—and serves notice that the SEC will continue to put a high priority on customer well-being.