- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Aaron Nicodemus2023-03-23T15:22:00
What is compliance resiliency, and why is it crucial for your organization to have it? Recent enforcement examples demonstrate why mapping out a clear business continuity plan can help thwart a risky management reshuffle.
Compliance resiliency is the process of thoughtfully ensuring a firm’s compliance function is not compromised or weakened by the absence of a key employee. That employee might be the only full-time compliance officer in the company, or their compliance responsibilities might be siloed in such a way that no one else knows exactly what they’re doing and how they’re doing it.
A small Puerto Rican bank and a New York-based investment adviser were recently subject to enforcement actions due in part to their failure to understand and plan for the unexpected departure of a key compliance officer.
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When the DOJ released its revised Evaluation of Corporate Compliance Programs, it turned some heads. Tucked into a section on risk assessments was a strongly worded series of questions that appeared to shoulder compliance teams with the responsibility for ensuring the safe use of AI tools by their firms.
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