How Defensible Is Your Compliance Approach?

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About this time each year – when the SEC’s Office of Compliance Inspections and Examinations (OCIE) releases its annual Examination Priorities – we are reminded of how complex compliance can be for SEC-registered firms. As Duff & Phelps’ Chris Lombardy explains, this year is no exception.

In its 2019 Examination Priorities, issued on December 20, 2018, OCIE has outlined six themes that it will primarily, but not exclusively, focus on in the coming months. One new theme, digital assets, joins the five priorities that repeat from 2018:

  1. Matters of importance to retail investors, including seniors and those saving for retirement
  2. Compliance and risk in registrants responsible for critical market infrastructure
  3. Select areas and programs of FINRA and MSRB
  4. Digital Assets (cryptocurrencies, coins and tokens)
  5. Cybersecurity
  6. Anti-money laundering

(See graphic at the end of this article for a select view of the 2019 OCIE Examination Priorities.)

Combined with recent Risk Alerts issued by OCIE, the Exam Priorities highlights that compliance at SEC-registered firms requires having visibility into not only finance (middle and back office) and trading activities, but also marketing, research and information technology.

In this article, we will explore some recurring key areas in OCIE…

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