Published on Feb 15th, 2024 |

Importance of a Strong Culture of Compliance | Chelsea Bosiljevac Insights

Vigilant Insights


The most recent SEC enforcement involving recordkeeping and off-channel communications reinforces our opinion that there will be no slowing down for the Agency when it comes to electronic recordkeeping compliance. Over $2.75 billion has been charged to Firms since the SEC initiated these investigations.

Vigilant Director, Chelsea Bosiljevac, Esq., IACCP®, provided her insights into this recent development in a FundFire article published this week.

Chelsea Bosiljevac’s Insights

Chelsea Bosiljevac’s Insights

When it comes to enforcement actions that take place, it is noted that senior personnel were charged with failing to supervise the employees that were routinely using off-channel communication. Chelsea indicates the need for Firms to have a strong culture of compliance, and that the SEC is emphasizing the responsibility of compliance starting “at the top”.

Due to these regulatory actions, she has found many Firms are outright prohibiting the use of messaging apps for all employees.

Vigilant's Conclusion

Vigilant’s Conclusion

The SEC has repeatedly mentioned in their charges that the penalties will continue until the industry shows signs of permanent change.

It is vital that Firms evaluate their recordkeeping process for electronic communications and review. Clear policies and procedures must be written and enforced involving off-channel communications.
It can be difficult to balance the need for cost-effective solutions while limiting regulatory risks, and professional compliance support can provide the necessary experience and insights needed to help make these decisions.

Please reach out to us today to if you are in need of support.

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