A company new to Ethics & Compliance has to implement 4 different internal mechanisms to stay aligned to its legal obligations: (i) a whistleblowing system, (ii) an AML screening system, (iii) a Conflict of Interest policy that it is also connected to PEPs, and (iv) an ABAC policy. All are top-1 priorities and all have a strict deadline: in 2 weeks, an audit team will visit the company for its first monitoring meeting. This is not something new for the company; it tried to hire an Ethics & Compliance for the past 6 months without any success. Mainly, because the budget for this position is very low. This is also indicative for the interest of the company in this function.
In order to move forward, the company opened the job internally and a sales agent applied. Gina is the new Ethics & Compliance Manager and she is … the entire department. What would recommend her to do first?
*You need to take into consideration the fact that the monitoring visit cannot be postponed due to other deadlines. **Secondly, if this company fails to receive the approval of the audit team, it will have its licence suspended for 6 months according to an agreement with prosecutors. ***The company is not located in US nor subjected to US regulations.
CASE STUDY INFORMATION
Author(s): Cristian Ducu
General Area: Business Ethics
Specialized Field: Ethics & Compliance
Keywords: Anti-Money Laundering, AML, Conflict of Interest, Monitoring, Publicly Exposed Persons, PEP, Whistleblowing
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