The following sovereign wealth funds are part of the Internal Working Group of Soverign Wealth Funds and the Santiago Principles: Australia The Future Fund Azerbaijan State Oil Fund of the Republic of Azerbaijan Botswana Pula Fund Canada Alberta Heritage Savings Trust Fund Chile Economic and Social Stabilization Fund / Pension Reserve Fund China China Investment … Read more »
Category: Compliance Programs
The Santiago Principles
The International Working Group of Sovereign Wealth Funds created a set of 24 best practices called the Generally Accepted Principles and Practices (GAPP) or the Santiago Principles: GAPP 1. Principle The legal framework for the SWF should be sound and support its effective operation and the achievement of its stated objective(s). GAPP 1.1 Subprinciple The … Read more »
Policy Lifecycles
Sumner Blount of CA puts together his thoughts on the lifecycles of policies:Policy Lifecycles: The Foundation for a Unified GRC Approach. As you can easily see, it’s a constant feedback loop, where policies are devised, controls are created and tested, and risks adjusted based on the success of those controls. Read more »
Politically Exposed Person
Politically Exposed Person “PEP” is a person who may be or recently acted in the political arena of a country or has held a position in the recent past. These individuals must be tracked by financial institutions as they pose potential risk. PEP-specific compliance legislation underlines the link between corrupt politicians, money laundering and the … Read more »
Financial Services Authority Anti-Money Laundering Handbook
The United Kingdom’s Financial Services Authority has their full handbook online including a section on compliance. Read more »
A Unified Approach to GRC
A participated in a webinar by Carole Stern Switzer of OCEG and Sumner Blount of CA, Inc. on Unified Governance, Risk and Compliance. Governance – the culture, policies, processes, laws and institutions the define the structure by which companies are directed and managed. Risk – the effect of uncertainty on business objectives. Compliance – The … Read more »
Why Use a Hotline?
Is it important to have a hotline for reporting violations? Reporting violations is a keystone for an effective compliance program. It can maximize the eyes watching for lapses in judgment and blatant violations. It can foster the reporting of issues and concerns as they occur or before a violation occurs. Read more »
Ethics as a Business Process
Adam Turteltaub wrote Ethics as a Business Process for the fall 2005 edition of GRC 360. Forward-looking companies are seeking to evolve business from soft art to hard science as a means to win in the marketplace, improve competitive advantage, achieve higher market valuations, ensure employee retention, foster fruitful partnerships and strengthen customer satisfaction. . … Read more »
Compliance at The Nature Conservancy
Back in 2004, The Nature Conservancy created the job of Chief Compliance Officer and formalized is compliance and governance policies. There is an interview with Karen Berky, Chief Compliance Officer in The Nature Conservancy’s 2004 Annual Report: Conservation That Works. Ms. Berky talks about the Conflict of Interest Policy and the Conflict of Interest Standard … Read more »
Evaluation of the Chief Compliance Officer
Thompson Hine put together a paper: Evaluation of the Chief Compliance Officer: While Rule 38a-1 under the Investment Company Act requires a Board of Directors to approve the appointment, removal and compensation of a fund’s Chief Compliance Officer (“CCO”), the rule is silent as to any requirement to annually review the performance of the CCO. … Read more »