Representative Engagements

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.

A large European bank retained Promontory to conduct a preliminary assessment of its existing compliance risk management structure and controls and processes, with a particular focus on meeting Bank Secrecy Act and anti-money laundering (BSA/AML) regulatory requirements. Promontory helped the bank develop a compliance plan to strengthen its BSA/AML compliance policies and procedures, including the risk assessment of its current customer base.