Compliance Bricks and Mortar for May 17

MontelibrettiPalazzoBarberini bricks

These are some of the compliance-related stories that recently caught my attention.

White: SEC’s No. 1 priority is more adviser examinations By Mark Schoeff Jr. in Investment News

The Securities and Exchange Commission’s top priority is to increase the number of investment adviser examinations it handles every year. How to go about doing that is another question.

“Significant additional coverage is essential if investors are to be appropriately protected,” SEC Chairman Mary Jo White told lawmakers today, pointing out that in fiscal 2012, the agency examined only 8% of registered investment advisers, who now number about 11,000.

The Importance of a Senior Executive Compliance Committee by Michael Volkov in Corruption, Crime & Compliance

We all know that corporate boards play an all important role in an effective compliance program. Not as much attention is paid to the operation of senior executive compliance committees. This is a different animal than the compliance committee at the board level. A senior executive compliance committee consists of the key senior corporate officers needed to carry out an effective compliance program.

A PWC Compliance Survey conducted last year found that 71 percent of surveyed companies have a senior executive compliance management committee. But not all committees guarantee success. Some committees work well and some do not.

Four Keys to Compliance Leadership by Tom Fox

I recently read an excellent article it the Corner Office section of the New York Times (NYT), entitled “We’re Family Yes, but We’re Still Accountable”, in which Adam Bryant reported on his interview with Brooke Denihan Barrett, the co-Chief Executive Officer (co-CEO) of the Denihan Hospitality Group (Denihan), a 50-year old family business which focuses on the hospitality business.

Hiring and Promotion

Reflections on the updated COSO Internal Control Framework by Norman Marks

I am still in the process of my detailed review of the update. However, I have already formed two opinions:

1. The assertion that “an effective system of internal control reduces, to an acceptable level, the risk of not achieving an entity objective and may relate to one, two, or all three categories of objectives” is excellent and I am pleased that it comes before any discussion of principles

2. The assertion that follows, that this (reducing risk to an acceptable level) requires that “each of the five components and relevant principles is present and functioning” creates a serious problem

Marketing The FCPA … The FCPA Risks Of … Well, Just About Everything by Mike Koehler in the FCPA Professor

It is a common FCPA Inc. marketing device.

Pluck any FCPA-related item from the news and use that news as the hook to write about FCPA compliance services.  Profile any recent instance of FCPA scrutiny and use that scrutiny as the hook to write about a supposed new trend and how that new trend of course indicates the need for FCPA compliance services.

It seems as if everything now-a-days is a “sobering reminder,” that there is constant speculation as to which industry “is going to be the next target,”  and that every company is warned to ask itself will it be prepared when the ”government knocks on the door.”


Image is the Palazzo Barberini a Montelibretti, herringbone bond wall.