When a problem in the compliance department arises, people often question the policies. However, it is what you do in the wake of potential violations that shows how seriously your firm takes and handles conflict of interest issues.
We recommend that you review your conflict of interest policies regularly and then look at the systems you have in place to monitor, detect and prevent violations of your policies. Are all of your internal systems working with each other? Is the money and time you have spent creating a system to manage potential conflicts of interest living up to its expectations?
By using StarCompliance’s system, you will have the ability to leverage our developmental expertise and regulatory insights to reduce your risk of violations saving your firm, substantial fines and possible jail time for stakeholders.
It is important to trust your employees but also to have systems in place to verify the information is valid. As in the case of Yi Chen, CPA (SEC Administrative Proceeding File No. 3-17361) who served as a Corporate Controller, which allowed her access to confidential financial information and was trusted to comply with the policies and procedures in place to prevent insider trading. Clearly, the SEC’s view is that she violated that trust.
We invite you to take the time to re-evaluate what you are using to monitor, detect and prevent insider trading, and compare it to StarCompliance’s configurable compliance solution.