With recent enforcement actions reflecting the Gensler administration’s priority on books and records, can your firm's audit trail stand up to regulatory scrutiny?
Recent enforcement actions have made it clear that Chief Compliance Officers are at risk of personal exposure if regulatory violations happen under their watch. The New York City Bar Association recently released a report calling on financial regulators including the SEC and FINRA to adopt a comprehensive and analytical framework for holding CCOs personally liable for violations.
The SEC Division of Examinations, formerly known as the Office of Compliance Investigations and Examinations (OCIE), provided a discussion of key risks and trends in its 2021 Examination Priorities document.
The benefits and affordability of current compliance technology are well known to regulators. Recent SEC guidance and risk alerts have consistently pointed to a lack of adequate technology as a deficiency in compliance programs. Could minimum technology standards for compliance be far behind?
Taking a look back can help you move forward. Now’s the time to take a step back and consider how new or elevated risks during the year have been addressed, how controls have been established, and how compliance initiatives undertaken at year-end can set the stage for a stronger compliance program in 2021.
