Watch that sign-in sheet

This is more general compliance stuff, but the rules are the same whether one is talking compliance with law or compliance with company policy.  Isn’t it?

The question:  did someone know what the rules were?  If so, you can punish more severely.  If not, your training/communication system has a flaw.

“Martoma Was Trained in Rules,” Wall Street Journal, January 17, 2014 C3 http://on.wsj.com/1ad9ksR  The accused kingpin of the insider trading violation at SAC Capital Advisers attended two compliance training sessions.  The compliance officer who ran those sessions says they covered the prohibitions on insider training.  He had his PowerPoint slides.

So, in the battle of who’s liable under the Federal Sentencing Guidelines, Mr. Martoma, SAC, or both, the question comes down to whether the rules were adequately communicated (and enforced).

 

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Filed under Business Case, Communications, Compliance, Controls, Governance, Information, Internal controls, Legal, Policy, Requirements, Risk

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