THE TUSK: Bits of Compliance Advice from Elinphant

Welcome to the inaugural edition of The Tusk, my personal perspective on current issues that we all face in compliance. My goal is not just to summarize new regulatory developments but to offer comments that are practical and tactical. I hope you enjoy. Reflections I think it’s time for regulators to reconsider whether it makes sense for firms…Read More

Your Employees Are Probably In The Crypto Markets. Here’s What To Do

This week, Elinphant CEO Elin Cherry lends us her expertise in handling this increasingly common situation Cryptocurrency has arrived in force, and it's not just Bitcoin anymore., a market tracker, currently lists 1577 cryptocurrencies being traded on 10417 cryptocurrency exchanges, with an emphasis on currently. Check back tomorrow and either number may have gone up, or…Read More

Cryptocurrency Employee Trading, Investments and Activities

Employees are participating in the cryptocurrency marketplace and firms need to address and supplement their employee trading, private transaction and outside business activity policies expediently. Although cryptocurrency and the cryptocurrency marketplace are novel, most of the activity is covered within current employee trading, private investments and outside business interests policies. However, many firms have not…Read More

Not Fake News: FINRA 2018 Priorities

Adaptions and “CliffsNotes” version of FINRA 2018 Priorities. All opinions are my views and do not necessarily reflect FINRA guidance. My recommendations offer proactive advice to address FINRA priorities in anticipation of a FINRA examination, sweep letter or inquiry. I adjusted the topic structure to emphasize the priorities that I believe are newer, difficult to…Read More

FRAUD: Books & Records

Books and Records or lack thereof have become a focal point for regulators. Whether FINRA, SEC or MiFID II the requirements have become prescriptive. Audit trails are detailed; regulators utilize the audit trails to identify market patterns and fraud; these audit trails are required to be maintained as Books and Records. In the US, the…Read More

Let’s Talk Supervision: Freedom with Responsibility

Are you at Risk? Efficient and Effective Supervision In 2016 FINRA brought 1434 disciplinary actions against registered individuals and firms, and levied $176.3M in fines. With the ongoing onslaught on new social media channels, voice, mobile, and messaging apps entering the workforce, are you able to capture and review all communications used by your firm…Read More

Elin is Speaking on Wednesday August 23rd – FINTECH WEEK

Elin is the CEO of Elinphant a financial compliance services firm. Elin ensures compliance officers who serve clients are skilled and knowledgeable in relation to the clients business and needs. Elin is known for looking at compliance challenges as well as marketing and sales in an innovative and direct manner.Read More

5 Steps to Managing Risk in Your Growing Company

A five-step process that guides the development of a governance and controls framework to protect your organization from the ever-increasing world of risks. (As featured in YPO Ignite Magazine, July 19, 2017) We all make mistakes. When I was working for a hedge fund, I watched one trader sell a bond to another trader —…

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Rudimentary Compliance Reflections – Blockchain/DLT

“There is a risk of innovating as well as well as not innovating” Bethany Dugan, OCC, Deputy Comptroller of Operational Risk   Basic Terms: DLT (“Digitial Ledger Technology”): a form of technology such as Blockchain. Smart Contract: Contract between parties is written into code. The triggering event occurs and contract executes itself according to the…

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