Compliance Bits and Pieces for March 5

Here are some compliance related stories from the past week:

Setting Off Alarm Bells at Work by Steven D. Levitt on Freakonomics

Apparently, the use of such internet sites [Facebook]  is not tolerated by CPS and rather than block those websites altogether, accessing them causes this ear-piercing noise to go off that sounds something like a fire-department wagon passing directly by you.

The firm gives the workers an incomplete list of which sites are banned.  Thus, the worker can never be quite sure when they go to a site that should be banned (but may or may not actually be alarmed due to the difficulty of identifying and banning every naughty site), if they will trigger the alarm.

CNBC Video: Madoff Whistleblower Speaks from Securities Docket

CNBC’s Mary Thompson’s interview with Harry Markopolos, the Madoff whistleblower who is now promoting a book on how he he tried to warn the SEC and others about Madoff’s Ponzi scheme.

The Depressing Tone of Bank of America by Matt Kelly of Compliance Week

Sometimes corporate leaders step up and do the simple, ethical thing, and their tone at the top is a harmonized chorus delightful to hear. Sometimes they do the wrong thing, and their tone is more like a tribal screech of self-interest.

Internal Review of a Proposed Foreign Business Partner by Thomas Fox

A Foreign Business Partner Review Committee should be established which is tasked with reviewing all the investigative due diligence and the Business Unit’s case for partnering with the person or entity. The next area of review should of the proposed Foreign Business Partner’s ethics and compliance program. Such a program should have, at a minimum, the following elements of a Foreign Corrupt Practices Act (FCPA)-style compliance program in place.

To Be or Not to Be Honest with the SEC by Suzanne Barlyn in the WSJ’s Financial Advisor

Weighing the risks and rewards of voluntarily reporting compliance lapses to the Securities and Exchange Commission is a tricky issue for investment advisers. Gene Gohlke, associate director of the SEC’s Office of Compliance Inspections and Examinations, recently tried to ease advisers’ concerns about self-reporting violations that their compliance programs catch, such as certain trading errors.

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