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In the face of the COVID-19 pandemic, protecting vulnerable consumers is a regulatory priority. Recently, the SEC has emphasized the need for maintaining market integrity and following controls and procedures. In addition, recent SEC and FINRA actions have shown that enforcing conflicts of interest remains a priority and conduct risk-based inspections will continue to advance.

Gifts and entertainment compliance can be difficult to handle but they are an essential part of business relations for many companies. We all agree it helps to improve business relationships. However, gifts and entertainment can also create compliance risks such as bribery for government and politically exposed persons, inappropriate influences from vendors, violations of the policies of third parties and manipulation of laws and regulations. That's is why it is so important for the compliance team to understand and mitigate the risks. 

Addressing Conflict of Interests (COI) that can have an outsized impact on the overall efficacy of a firm’s compliance and ethics program should be a top priority. The danger of poor COI mitigation is not only the immediate impact from individual COIs but also a broader risk to the entire program.

As the June 30 deadline approaches, the SEC has yet to provide an extension to Regulation Best Interest as part of their response to the COVID-19 crisis. Firms must be ready to comply even as they deal with trying to conduct business as usual in a climate of flux and uncertainty.

With March deadlines looming, is your organization ready to provide a substantive annual compliance report?