Fairwords Weekly: Electronic Communications Tips, Compliance Technologists, and DOJ/SEC Objectives
October 27, 2022
“Companies should feel empowered to do the right thing—to invest in compliance and culture, and to step up and own up when misconduct occurs.”
— General Lisa O. Monaco, Deputy Attorney, United States Department of Justice
This week, we explore why it is crucial for compliance professionals within financial service firms to demonstrate their abilities with new technologies to meet regulatory requirements. Discover five compliance tips for handling electronic client communications put together by attorneys specializing in broker and advisor regulatory issues. Also, learn how the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) promote parallel objectives regarding individual accountability, timely disclosure, and more—and what it means for your organization.
On September 15, 2022, Deputy Attorney General Lisa A. Monaco gave a memorandum that clarified a series of DOJ objectives regarding corporate and individual responsibility that parallel recent statements from leaders in the Division of Enforcement at the SEC. The current SEC demands stronger gatekeeper accountability, early cooperation with enforcement proceedings, individual financial punishment, and penalties that proportionately address recidivism. This coordinated, dual threat of enforcement by both the DOJ and SEC suggests that companies should refine their compliance programs and front-load their internal investigations to facilitate timely and complete disclosure of information that pertains to individual conduct. Learn more about these dual objectives and the six steps organizations should take to answer them.