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Employee Conflicts of Interest Outside Business Activity

How Do I Manage Outside Business Activities?

A guide for compliance officers in enterprise financial firms

Outside business activities are always on the shortlist of serious concerns for compliance departments when it comes to locking down potential conflicts of interest. The kind that typically cause the most heartburn for hardworking compliance officers include:

  • Family members or similarly connected individuals working at other firms
  • Board-level roles outside the firm
  • Charitable donations
  • Directorships

As with so much of modern business life, software is the key to successfully managing this universally daunting compliance challenge. Here’s what well-designed compliance-monitoring software can do and how it can help.

Like all enforcement professionals, compliance officers want to catch problem activity at the earliest possible point. And there’s no earlier point to catch such activity than before it even starts. In this sense, pre-clearance is the compliance officer’s most important tool.

This means employees should have to pre-clear any proposed outside business activities with compliance before they’re given permission to proceed. Good compliance software will automate these permissions and denials, with the platform’s rules engine taking into account your firm’s operating polices and code of conduct. This will allow employees to not just quickly and easily submit pre-clearance requests but to also make external business declarations.

Look for a vendor that can integrate your firm’s HR system into the compliance platform, so all employee details are taken into account, including historical business activity records. Make sure the platform doesn’t put any restrictions on the number of external activity declarations that can be submitted or on their content. You should also be able to customize the wording, question types, and format of your declarations.

Finally, in cases where a rapid approval or denial isn’t possible, the right compliance software will automatically escalate such requests or declarations to a multi-level review process you determine.

Certifications and attestations are your enterprise financial firm’s proof of regulatory rigor. Good software will allow your compliance team to automatically collect and store regulatory certifications and attestations from firm employees: providing an extra measure of proof your business is doing everything in its power to detect and prevent conflicts of interest, if auditors ever come knocking.

By submitting attestations, employees confirm that all recorded information, business activities, and transactions are accurate and comprehensive. At intervals you determine, the compliance platform collates all data on each employee into an attestation or certificate for them to review. All approved certificates should be stored by the platform for future reference, to be viewed or downloaded by your compliance team on demand.

Good software can also push information out to employees. This could include the latest firm policies, or breaking changes in regulation—anything that someday might buttress a case to industry watchdogs that you’re doing everything you can to ensure regulatory compliance.

Reports make the business world go round, and enterprise financial firms are no exception. Whether they’re helping compliance officers get a handle on things in their corner of the company, or keeping the c-suite similarly informed, reports keep management at all levels in the know.

Look for compliance software that offers a comprehensive reporting and management information suite. This will give teams a 360-degree view of employee behavior and activity, ideally allowing them to search for data in any field and export information for further analysis. Some platforms offer 100 standard reports or more. You should also be able to design and create reports to suit any specific needs. Finally, the ability to produce sophisticated visualizations, graphs, and charts should be a given with any modern compliance software.