MyComplianceOffice Blog

The UK Bribery Act was implemented nearly eight years ago, but no case law exists to offer organizations an interpretation of corporate hospitality rules. The sole source of guidance to date has been from the Ministry of Justice in 2011.  

Earlier this year, the National Futures Association (NFA) put forth guidance to commodity pool operators (CPOs) on the regulator’s Compliance Rule 2-9 that took effect on April 1. The guidance (aka “the Notice”) applies to CPOs with control over customer funds. It outlines what CPOS should be doing to manage employees and how they should be supervising third parties in order to meet their obligations under the new rule focused on internal controls.  

There’s not much available from UK regulators on what they expect from an overarching corporate compliance program. Most guidance issued to date has focused on prescriptive compliance with specific regulations. But UK corporations can look to the U.S. Department of Justice (DOJ) for a solid program template. 

Chances are your organization has developed a conflict of interest (COI) policy. But does it have an effective COI compliance program in place? Can you demonstrate it to regulators? If the answer is no to either of those questions, there are three things you need to do now to satisfy regulators that you take COI prevention seriously.  

All too regularly, we see headlines of another case of insider trading; a recent list of offenders that includes everyone from Goldman Sachs employees to football players. Compliance industry professionals are aware that insider trading laws are complex and vary significantly from country to country. The extent of enforcement also varies from one country to another, with penalties that could cost businesses millions.  Prevention of insider trading begins with the implementation of adequate policies and procedures, along with the development and maintenance of comprehensive records to ensure regulatory guidelines are met.