[author: Matt Kelly]
The coronavirus crisis is far from over, and compliance professionals still need every scrap of guidance that regulators can provide about how to run compliance programs in these difficult times.
So when the Securities and Exchange Commission published its latest risk alert the other week, I took notice. Even though the guidance was written for broker-dealers and investment advisers, it deals with subjects including policy management, risk assessment, and data security.
Well, those things challenge every compliance officer, regardless of industry. So let’s see what lessons can be extrapolated for corporate compliance programs generally.
Personnel and Policy Matters
This risk alert came from the SEC’s Office of Compliance Inspections & Examinations, and OCIE uses the phrase “supervision of personnel” quite often in its material. That conjures up an image of managers watching over employees on a sales team, but the term actually means much more — and raises an important point for compliance officers.
OCIE’s full description of “supervision of personnel” in its risk alert is this:
A firm’s supervisory and compliance program…
