#compliance procedures

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Procurement Coordinator at Emerson Process Management

Procurement Coordinator at Emerson Process Management

Emerson Process Management, an Emerson business, is the global leader in helping businesses automate their production, processing and distribution in the chemical, oil & gas, refining, pulp & paper, power, water & wastewater treatment, metals & mining, food & beverage and pharmaceutical industries.

Emerson combines superior products and technology with industry-specific engineering,…

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Sylvia M. Scott: Creating a Strong Compliance Program

A partner at Freeman, Freeman & Smiley, LLP, in Los Angeles, Sylvia M. Scott also serves as head of its Securities Regulation Practice Group. Responsible for defending brokers and advisers, Ms. Scott (formerly a regulator with the SEC and FINRA) understands the importance of identifying potential compliance problems before they become enforcement referrals.  Virtually every investigation or examination by FINRA and the SEC considers the issue of supervision and the adequacy of a firm’s written supervisory and compliance procedures (“WSPs”). If the regulators believe that the misconduct at issue could have been prevented or detected with a “reasonable” supervisory system or “reasonable” supervision, then the supervisory and compliance staff will be evaluated to determine whether they should be held accountable for the alleged deficiencies.  In view of the aggressive stance taken by the regulators these days with regard to supervisory liability, adopting a plan for minimizing one’s regulatory exposure should be of paramount importance to firms. The following are some tips for avoiding supervisory liability: 1. Clear & Concise WSPs Regarding Reporting Lines: Make sure the WSPs: 1) clearly identify the direct line supervisors of all financial advisers; 2) state that it is not the firm’s intention to make legal and compliance staff the supervisors of financial advisers; and (b) clearly state that legal and compliance staff do not themselves have the responsibility, ability or authority to effect the conduct of financial advisers (or define the limited areas where they do have any such authority).  2. Document Red Flags & How They are to be Handled: Document in a memorandum, report and/or email significant issues regarding potential employee misconduct, including how the issue is to be handled going forward and which direct line supervisors will be responsible for implementing and monitoring the employees conduct. Note well: Documenting this type of event is always a sensitive undertaking and should be approached with appropriate caution and legal guidance. 3. Training: Make sure the staff compliance staff receives adequate training and support to enable them to do their jobs. Of course, meaningful training for advisers is also critical. In this ever-changing regulatory landscape, this is a particularly important area.  4. Communication with Supervisors: CCOs should make sure that the direct line supervisor of any employee whose conduct has raised red flags is aware of the issues and is implementing a plan to respond to the red flags. This must be documented. 5. Heightened Supervision: Heightened Supervision Plans must be documented and should include: 1) the details of the plan; 2) assigned supervisory responsibilities for implementation of the plan; 3) how the plan will be monitored and by whom. 6. Escalate: Unresolved compliance issues should be escalated up the chain of command. There should be clarity around who is making decisions relating to the matter.  7. Carefully Evaluate Expansion of the CCO Role: Carefully evaluate the assignment of any new responsibilities and whether they entail any supervisory responsibilities. Individuals who take on supervisory duties may unwittingly assume liability if violations occur in their areas. This is what occurred, according to the administrative law judge, in the Urban case.  8. Role on Committees: Carefully evaluate the ramifications of undertaking roles on firm committees. If you serve on firm committees and/or the board of directors, make sure that it is clarified in writing that your role is advisory in nature and nothing more. This was a factor identified in the Urban case which contributed to the administrative law judge’s determination that Mr. Urban was a “supervisor.” 9. Ensure Sufficiency of Compliance Resources: If you must wear multiple hats, be realistic about whether you can actually discharge all of your compliance responsibilities. The cost of a regulatory action (and any related private actions) can be significant and put a small firm out of business.  10. Alternative Products: If your firm sells alternative products (Reg D offerings, private placements, etc.), among other things: 1) make sure your firm has a rigorous and ongoing due diligence program; and 2) consider creating a short, “plain language” disclosure form for each customer to sign that spells out that they understand the product is high risk and that the investor could lose all of his/her money. This area has resulted in a plethora of supervision cases by FINRA and the SEC. While much of this is easier said than done when trying to run a business in this challenging economy, through planning and smart management it can be done.

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New Post has been published on Trading Review 360

New Post has been published on http://tradingreview360.com/sands-beefs-up-anti-money-laundering-safeguards-wsj.html

Sands beefs up anti-money laundering safeguards - WSJ

[US Market News] TradingReview360.com: We search to deliver you the breaking news stories from around the globe. The article below is sourced from the latest US Market News.

Read on to learn more:

NEW YORK (Reuters) – Las Vegas Sands Corp is no longer making international money transfers for its high-end casino customers and is revamping its compliance procedures as it faces regulatory scrutiny, the Wall Street Journal reported, citing people familiar with the matter.

The casino operator, which is the subject of a money-laundering investigation by U.S. authorities, has recently hired three former FBI agents to beef up its anti-money-laundering efforts, the Journal reported.

U.S. regulators are taking a look at the casino industry and considering tougher rules to combat money-laundering, the Journal said, citing Treasury Department officials.

The Sands, controlled by billionaire Sheldon Adelson, is also planning to improve the background checks the company does on its VIP customers and is retraining its staff on U.S. antibribery laws.

Sands has been in talks with U.S. authorities to resolve a probe into whether the casino failed to alert officials about suspicious transactions of two high rollers at its Las Vegas casino, people familiar with the matter told the Journal.

A spokesman for Sands did not immediately respond to a call from Reuters seeking comment.

A spokesman for the Sands told the Wall Street Journal: “We have and will continue to build and enhance the best compliance processes in the business because we are leaders and good corporate citizens.”

U.S. law requires casinos to report suspicious money transfers.

Regulatory changes could impose other requirements, such as collecting identification records for high-end customers and doing more research on customers’ sources of funds, the Journal said, citing people familiar with the matter.

(Reporting By Dena Aubin; Editing by Chris Gallagher)

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