Compliance Bricks and Mortar for February 28

curling and compliance

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

Are You a “Rat Trader?” by Bruce Carton in Compliance Week

Today I stumbled up on the following headline from the Chinese publication, Global Times: “Rat trader faces 5-10 years for insider dealing.” Rat trader?? It turns out that in China, at least, “rat trading” is the phrase used to describe what we would call “front-running” in the U.S.

Commitment to Compliance: the Compliance Committee by Tom Fox

One of the commitments I believe can enhance a compliance program is the creation of a compliance committee. As far back as in the 2005 Monsanto Corporation Deferred Prosecution Agreement (DPA) the compliance committee concept appears to have found favor with the Department of Justice (DOJ). In Appendix B to the DPA, Monsanto agreed to, among other things, “the establishment and maintenance of a committee to supervise the review of (I) the retention of any agent, consultant, or other representative for purposes of business development or lobbying in a foreign jurisdiction”, or a Compliance Committee. Later, this concept was used in the settlement of Halliburton’s shareholder action around its Foreign Corrupt Practices Act (FPCA) enforcement action.

SEC’s Newest Enforcement Weapon: Powerful Software in Money News

Officials expect Palantir’s platform to help the SEC find evidence of illegal activity more quickly and easily by linking trading records and personal contact information from paid databases with tips, complaints and referrals the agency has received, said the sources, who were not authorized to speak publicly about the matter.

A human-readable explorer for SEC filings in Flowing Data

Maris Jensen just made SEC filings readable by humans. The motivation:

But in the twenty years since, despite hundreds of millions invested in rounds of contracted EDGAR modernization efforts and interactive data false starts, the SEC’s EDGAR has remained almost untouched. In 2014, the SEC is quite literally doing less with SEC filings than their predecessors had planned for 1984. Data tagging is the red-headed stepchild of the Commission — out of hundreds of forms, only about a dozen are filed as structured data — and the first program to automate the selection of SEC filings for review, the Division of Economic and Risk Analysis (DERA)’s ‘Robocop’, has been ‘aspirational’ for years. The academics in the division responsible for the SEC’s interactive data initiatives write papers about information asymmetry, using EDGAR data they repurchase in usable form for millions each year, but do nothing to fix it. Companies are chastised for insufficient and inefficient disclosure, while the SEC fails to help retail investors navigate corporate disclosures at all.

How Grocery Bags Manipulate Your Mind by Carmen Nobel in HBS’ Working Knowledge

People who bring personal shopping bags to the grocery store to help the environment are more likely to buy organic items—but also to treat themselves to ice cream and cookies, according to new research by Uma R. Karmarkar and Bryan Bollinger. What’s the Quinoa-Häagen-Dazs connection?

Above is a photograph of outdoor curling in Central Park in New York City. I love this picture, so I thought I would share it. More 1890s curling photos.