Although each regime has established its own unique set of terms and underlying expectations, the result remains the same; to strengthen individual accountability across an organization to mitigate risk and identify red flags sooner. Across each regime, the primary expectations remain relatively the same:
A detailed and documented outline of functions and responsibilities mapped to Senior Executives.
The ability to produce an audit trail and effectively report on all of the above.
A fit & proper assessment and certification of your employees who are carrying out controlled functions within your business.
A clear record of breaches related back to the conduct rule that are enforced through annual attestations.
Robust Reasonable Steps processes to record what Reasonable Steps your Senior Executives are taking to mitigate the risk of breaches occurring.
The underpinning of any good organization is the training and competency of its most important asset – its people. Built with accountability regimes in mind, Star T&C provides the oversight, record keeping, and process management capabilities you need to drive a culture of compliance.
Visit our extensive library of IAR resources for actionable advice and best practices related to specific regimes, including SMCR, IAC, IAF, and FAR.
20 Feb, 2024
The popularity of crypto assets among the public has skyrocketed in recent years, as people become more familiar with what they are and how they can access and use them. There are now over 20,000 cryptocurrencies in existence, with 17% of US adults saying that they invested in, traded or used a cryptocurrency in 2023. But as with traditional securities, conflicts of interest may arise when employees trade crypto assets, putting both the firm and individual employees at risk. Compliance teams must therefore take the necessary precautions.
20 Feb, 2024
As mainstream adoption of digital assets increases globally, regulatory scrutiny is on the rise. As with any asset, conflicts of interest may arise when employees trade crypto assets, putting both the firm and individual employees at risk. With Rule 204A-1 of the Investment Advisers Act of 1940 mandating that registered investment advisers adopt policies and procedures requiring their employees to report personal transactions and holdings in reportable securities, there is growing concern among firms that they may be held liable for the crypto trading activity of their employees.
16 Jan, 2024
FINRA released their 2024 FINRA Annual Regulatory Oversight Report on January 9th. There are a number of sections that are important for Star clients that we discuss and highlight below.
