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Compliance

Compliance is one of the top risks financial institutions face. At Promontory, global compliance risk management is central in our daily focus, including:

Compliance Program Design

Compliance Risk Governance
Policies and Procedures
Compliance Obligation Libraries
Compliance Risk Assessment Methodologies and Systems
Compliance Monitoring Programs and Systems
Compliance Issue Tracking Systems
Compliance Risk Reporting Packages for Board-level and Senior Management Reporting

Compliance Program Implementation

Compliance Staffing Plans
Temporary Compliance Staffing
Including Compliance Risk Management Objectives in Compensation Plans

Compliance Program Review and Testing
Investigation and Remediation of Compliance Lapses
Compliance Training Design and Delivery

Board-level Training
Employee Training (in-person and computer-based)
Specialist Training

Promontory’s compliance practice clients include investment advisers, hedge funds, investment companies, broker-dealers, securities exchanges, banks, insurance companies, and other public and private companies.

At the core of our practice is our grasp of the ever-greater challenges imposed on compliance officers. Our professionals, with long careers as corporate executives and senior-level regulators, have designed and operated compliance systems and have written and implemented regulations. Our advice is informed by our knowledge of evolving regulatory expectations and is mindful of the operational and structural challenges that compliance officers face in the current environment. We manage compliance crises, conduct special reviews, and develop thorough and efficient compliance programs.

In addition to general compliance work, we provide specialized advice in six specific areas:

Anti-Money Laundering/Bank Secrecy Act
Anti-Corruption/Bribery
Community Reinvestment Act
Consumer Protection, including Fair Lending
Data Protection & Privacy
Securities, Futures, and Over the Counter Derivatives

Representative Engagements

Promontory implemented a compliance risk assessment using our proprietary software for a large financial institution that was facing a downgrade of its regulatory rating for compliance risk management. Regulators cited the risk assessment as the reason the institution avoided the downgrade.
Promontory completed regulatory compliance review and restructed of one of the world’s largest nonbank financial services providers, with in-depth focus in the areas of anti-money laundering, the Bank Secrecy Act, and “Know Your Customer” requirements, helping the institution avoid onerous enforcement penalties.
A US state regulator required a large broker-dealer and investment adviser to hire an independent consultant to assess its controls over the use and protection of customers’ personal and financial information. Promontory was engaged to conduct a review of relevant policies, procedures and practices. We assessed the effectiveness of the design and implementation of existing policies, procedures and related practices to determine compliance with state and federal law, including the Gramm-Leach-Bliley Act and the Securities and Exchange Commission’s (SEC) Regulation S-P. Promontory reported its findings and recommendations to the client and to the government regulators.
A registered investment adviser to multiple hedge funds turned to Promontory for a review of its compliance systems and written compliance policies and procedures. We assessed the operational effectiveness of compliance policies, procedures and systems, and made recommendations to fulfill regulatory requirements and to meet industry best practices. Throughout the review, Promontory gave real-time advice to the client on compliance and regulatory issues and provided guidance to the client and its attorneys on working relationships with the SEC’s examination of enforcement staff.

Compliance

Representative Engagements

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