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Building an effective compliance risk assessment programme for a financial institution
A Compliance Risk Assessment programme can be a meaningful, utilitarian and genuinely beneficial risk identification and management tool. This paper outlines some key elements and practical considerations for conducting a CRA. By better identifying compliance risks and managing the drivers of these risks and behaviour, a CRA not only helps firms to reduce the occurrence of conduct events, but also enhances the way that firms do business.
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Stephanie Nicolas is a partner in WilmerHale’s Securities Department and a member of the Broker-Dealer Compliance & Regulation Group. Ms Nicolas has extensive experience handling a broad range of regulatory and enforcement issues and conducting compliance reviews and audits. She works with major investment banks and other financial institutions to develop policies and procedures for a range of activities, including regulatory reporting, supervision, information barriers and surveillance, equity and debt research, conflicts, capital markets, and trading and sales practice issues. Ms Nicolas received her Juris Doctor, magna cum laude, from Georgetown University Law Center, 1999 and her BA from Brown University, 1994.
Paul V. May is the Chief Compliance Officer of ABN AMRO Securities (USA) LLC and its New York affiliates. Previously, he was a compliance officer and regulatory counsel at RBC Capital Markets, ICAP, and Cowen and Company. Paul served as an attorney at the Securities and Exchange Commission Enforcement Division from 1990 to 1995 and then at Kelley Drye & Warren and at Steere & May, providing broker dealer regulatory guidance and representation to firms and individuals in securities law matters. He is a graduate of the College of the Holy Cross and Brooklyn Law School.