These are some of the compliance-related stories that caught my attention while waiting for the results from the Brexit vote.
BEST PRACTICES FOR TODAY’S CCO by Julie DiMauro in the FCPA Blog
In addition to knowing their regulatory-reporting obligations, compliance officers should understand what their managers do, what products and services their company offers and the systems that sustain these products and services.
If a compliance officer lacks this background, it can be acquired through research, on-the-job training, observing business associates, and asking for outside educational opportunities. [More…]
General Solicitation Under Rule 506(b) After Citizen VC: Guiding Principles and Best Practices by Richard M. Leisner in the D&O Diary
It is too soon to know the-long term compliance effects of Citizen VC and the Companion C&DIs. Today is a good time, however, for careful analysis of these recent SEC pronouncements and their underlying rationale and regulatory provenance.
With this analytical foundation, this article suggests how best practices for conventional issuers might evolve for permissible general solicitation activities in future Rule 506(b) private offerings that will not violate the prohibitions of Rule 502(c). [More…]
HERE ARE THE TOP 5 SONGS ABOUT COMPLIANCE by Nicole Rose
The fastest way to change someone’s state is through music. The rhythm and pitch are managed in areas of the brain that deal with emotions and mood. Even the thought of a song is actually enough to stimulate the senses and ignite a positive response. For example, if I mention “You’ll Never Walk Alone” by Rodgers & Hammerstein or “For once in my life” by Stevie Wonder, you’ll probably have it in your head for at least a few minutes. [More…]
Four Points on AML Compliance by Matt Kelly in Radical Compliance
We might dismiss contradictory regulators as a fact of life in compliance, but beware the larger point: if compliance officers get mixed messages about what regulators expect, you cannot develop a sound strategy to implement global AML programs. You can’t easily place big bets on new technology, or adopt global policies and procedures. Instead, you’re trapped reacting to one regulator’s request after another. And without an effective strategy, you can’t implement cost-effective techniques to manage compliance—you just throw bodies and money at the problem of the day. [More…]