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Tis the Season: Strategies for Gifts and Entertainment Compliance

It’s common practice to give holiday gifts to business associates, but the giving and receiving of gifts can be a compliance minefield if not managed properly. Even a gift that’s completely well intentioned can give off the appearance of impropriety. And what about entertainment, like tickets to events, holiday parties and dinners out?

Firms must have solid policies, procedures and controls in place to monitor, document and address potential conflicts of interest around gifts, entertainment and hospitality. And equally important, employees must be aware of the policies and the procedures they are required to carry out to be compliant.

Join MCO and Jane Shahmanesh from Adherence, LLC for an overview of what compliance should be doing to ensure gifts and entertainment compliance is on point this holiday season and beyond. Jane answers audience questions and  provides practical guidance including:

  • Regulatory trends and expectations
  • What makes a good gifts and entertainment policy
  • When is a gift acceptable, and when is it considered inappropriate?
  • What should compliance be doing to ensure employees are aware of policies and procedures?
  • How can technology help streamline the process for both compliance and employees


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Jane Shahmanesh is a Founding Partner and Managing Director at Adherence, LLC, a firm that specializes in regulatory compliance for financial service firms - and its affiliated law firm. Adherence focuses on providing outsourced compliance solutions which can include acting as or supporting the Chief Compliance Officer

Prior to founding Adherence, Jane worked as an in-house legal and compliance lawyer for a Who’s Who of financial institutions – including Lehman Brothers (where she counseled the bankrupt entity’s derivative unwind),  Goldman Sachs & Co. (where she ran a division of their Compliance Department), Credit Suisse (where she was the interim legal manager for CSAM and its hedge fund businesses), Citibank (where she was the General Counsel to the Private Bank), and Deutsche Asset Management (legacy Bankers Trust)(where she supervised the legal and compliance department).

She was also a Partner at McGuireWoods, LLP, one of the nation’s largest law firms. Jane currently teaches regulatory compliance at Pace Law School. She has a BA from Barnard College and a JD from American University.

Jane Shahmanesh
Managing Director, Adherence LLC