The Death Star was touted as the “ultimate power in the universe.” But a few proton torpedoes managed to destroy the entire station. It didn’t make into the trilogy, but I assume there would have been an ensuing investigation that would have looked at the failures that lead to loss. At least I imagined there … Read more »
The Jedi and Compliance Failures
My family has been re-watching the Star Wars movies in anticipation of this week’s premiere of Episode VII. While watching Episodes I-III, I wondered if the Jedi could have used some compliance strategies to help prevent their downfall. Two of the goals of compliance are (1) to deter people in your organization from doing bad … Read more »
Do As I Say, Not As I Do
As financial firms are the recipients of more and more reporting obligations from government regulators, I find it amusing to note when the lawmakers fail in their own reporting obligations. The Wall Street Journal is reporting that Senator Bob Corker failed to disclose millions of dollars in his financial reports. The senator is the third-ranking … Read more »
Compliance Bricks and Mortar for December 11
These are some of the compliance-related stories that recently caught my attention. A Compliance Plan or a Compliance Idea? by John Nocero in SCCE’s The Compliance & Ethics Blog Much of what we do is dictated by our compliance plan. But we also need to be able to react based on arising risks or incidental … Read more »
The State of CCO Enforcement Actions
I was at the IA Watch conference titled “Coping with Regulatory Change” and several presenters from the Securities and Exchange Commission in different panels took a fair amount of time saying that the SEC is not targeting CCOs for enforcement actions. This was in light of several SEC actions against compliance officers in the last … Read more »
PRI finalizes ESG questionnaire
The Principles for Responsible Investment Initiative has launched the Limited Partners’ Responsible Investment Due Diligence Questionnaire to encourage standardized due diligence on environmental, social and governance considerations in private equity. The LP Responsible Investment DDQ was developed in consultation with a working group composed of 41 LPs, funds of funds and GPs. There are 21 … Read more »
Happy Hanukkah
How Hanukkah Came to the White House by Jonathan D. Sarna in Forward.com The first president who took official notice of Hanukkah was one of the Jewish community’s least-favorite occupants of the White House, Jimmy Carter. In 1979, he ended 100 days of self-imposed seclusion over the Iran hostage crisis by walking to Lafayette Park, … Read more »
Compliance Bricks and Mortar for December 4
These are some of the compliance-related stories that recently caught my attention. Your next PR battle is brewing in Private Funds Management Last week, the California Public Employees’ Retirement System (CalPERS) released carried interest data that several media outlets were quick to spin as private equity somehow being more expensive than investors had realized, … Read more »
The SEC Goes After the Gatekeepers: Grant Thornton Edition
“Audit firms must be held responsible when systemic failures such as inadequate engagement procedures, staffing, or supervision cause the firms’ work to fall significantly short of expected standards, particularly when multiple audits and engagements are involved.” – Andrew J. Ceresney, Director of the SEC’s Division of Enforcement. The SEC recently brought separate cases against senior … Read more »
New York’s Proposed Anti-Money Laundering Regulations Could Send CCOs to Jail
To start with the obvious, helping terrorists and drug kingpins with their finances is bad. The US regulatory machine has been clamping down tighter on financial institutions who engage in this bad behavior. As the bad acts continue, the regulators keep tightening the regulatory requirements. The latest tightening of the screws comes from New York. … Read more »