The Securities and Exchange Commission recently convened a meeting of its Small Company Advisory Committee. Normally news like that would not be big news for securities professionals, except for one point of discussion: overhauling the definition of an accredited investor. We can probably all agree that the current definition is outdated. It was adopted in 1982, and based…
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Nothing beats a good “princeling” case under the Foreign Corrupt Practices Act for tough, teachable moments that a compliance officer should study. We have that example today, since Qualcomm just paid $7.5 million in fines and penalties to the SEC for its princeling offenses. So let’s take a look. The facts are straightforward. Qualcomm makes…
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Last Friday I had the pleasure of attending the Society of Corporate Compliance & Ethics’ regional meeting for Boston, a great event organized by local compliance hero Web Hull, one of the nicest people in the business. The agenda covered numerous important topics, so let me focus on one that compliance officers probably hear quite…
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There we were, me and a small group of compliance professionals, talking shop about where good compliance officers come from these days. One person, a recruiter for asset management firms, told the tale of how she recently placed a chief compliance officer at a hedge fund in the Midwest. This CCO was “a dream candidate,”…
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Compliance professionals talk all the time about the importance of a rigorous corporate culture and tone at the top—but rarely do we see such a vivid example of those two items like we did earlier this month thanks to the management spat at Bridgewater Associates, a huge hedge fund in bucolic Connecticut. Compliance officers couldn’t…
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We all know financial services firms are under tremendous pressure today to improve their compliance and risk management functions. What’s been less clear is how those pressures are influencing firms when they are selecting chief compliance officers. Now we have some better insight into that, and it raises some interesting career questions for compliance officers…
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Yesterday the Securities and Exchange Commission set another precedent in regulatory enforcement: for the first time ever, it reached a deferred-prosecution deal with an executive (rather than a company) over foreign bribery charges. This is not exactly welcome news for corporate compliance officers. The executive is Yu Kai Yuan, a Chinese national who worked in…
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On Saturday evening after news broke that Supreme Court Justice Antonin Scalia had died, I sent out this tweet (entirely in jest): Going to petition Obama Admin to nominate #compliance officer for SCOTUS vacancy. Who's with me? @tfoxlaw @BenDiPietro1, looking at you — Matt Kelly (@compliancememe) February 14, 2016 After all, why not? Everyone talks…
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Corporate compliance enthusiasts have one more item on their To Do list this winter: be sure to review and comment on ISO 37001, the draft standard for anti-bribery management systems. The International Standards Organization has been working on ISO 37001 since 2013, and the goal is a final standard approved and available by the end…
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One of the most slippery tasks for any compliance officer is measuring the effectiveness of your program. And we all know one of the go-to metrics that compliance officers use, even if many secretly wonder how informative that metric really is. We speak, of course, about “hotline statistics.” Just last month, Convercent and Ethisphere published…
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