Identifying and Overcoming Gaps in Compliance Surveillance

Effective surveillance plays a crucial role for compliance in maintaining regulatory compliance and safeguarding the firm from the effects of illicit employee behavior that leads to market abuse and market manipulation. Regulators fully expect that firms to have effective controls in place to monitor employee behavior and transactions for non-compliance, whether inadvertent or intentional.

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Best Practices in Policy & Procedure Management for Financial Services

Solid policies and procedures are the backbone of an effective compliance program, providing a framework for the consistent application of rules and requirements across the organization and third parties that the firm conducts business with.

But just having a library of policies isn't enough. The key is having policies and procedures that are clear, actionable, defensible, adhered to across the firm and consistently updated to keep pace with regulatory change. In the complex and volatile business environment that financial services firms are operating in, that goal is often easier said than done. 

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Practical Steps to Strategic Year-End Compliance

SEC Rule 206(4)-7 requires registered advisers to review policies and procedures at least annually to ensure that they are both adequate and effectively implemented. Year-end is the optimal time for firms to conduct internal assessments of their compliance program to be ready for the annual review and to set the stage for a successful 2024.

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Strategies for Gifts and Entertainment Compliance

A survey by Coresight Research estimate that the corporate gift giving market in the U.S will reach $258 billion in 2022.  That's a lot of potential gifts sent to employees, customers and vendors - and a lot of potential opportunity for conduct risk.

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eComms Compliance: Stay Ahead of the Game

With the recent spree of SEC enforcement around the management and preservation of eComms—to the tune of more than $1.5 billion dollars—now is the time for firms to be thinking about best practices for managing digital communications.

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