Maintaining a Financial Institution Code of Ethics and Compliance: Key considerations

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April 03, 2015


  • Risk assessment: What areas of the business pose the greatest ethics  and compliance risks, and how can they be addressed?
  • Ethics and compliance personnel: Will a separate ethics and compliance office be created? Will a chief ethics and compliance officer be designated? What seniority/authority will that person have? To whom will he or she report?
  • Role of senior management and board of directors: What will the roles of senior management and board of directors be? What should they do to create the appropriate “tone from the top”?
  • Code of conduct: What form will the code of conduct take? Will it set  out the company’s principles and aspirations or will it be more concrete? How detailed will it be? How will it be communicated to employees?
  • Policies and procedures: What policies and procedures are necessary to  govern employees’ conduct? How can employees be educated and trained on these policies and procedures?

About the author:
• Partner in the Washington, D.C. office of Jenner & Block LLP • Practice emphasizes all aspects of white collar criminal defense and internal investigations • Conducts regular seminars and workshops on criminal law and ethics • J.D. degree, Yale Law School; A.B. degree, summa cum laude, Harvard University • Can be contacted at 202-639-6017 or [email protected]


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