InterviewSolution
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Will I Need To Prevent Electronic Disclosures From Occurring? |
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Answer» No compliance program can ever prevent 100% of misconduct by corporate employees. Nor do the regulations state that you must prevent internal disclosures --including electronic disclosures -- from happening. If investigated, you will need to SHOW DUE diligence that you have the ABILITY for an appropriate and RAPID response to detect and deter misconduct that exposes your COMPANY to operational risk that may have a material effect on your business. No compliance program can ever prevent 100% of misconduct by corporate employees. Nor do the regulations state that you must prevent internal disclosures --including electronic disclosures -- from happening. If investigated, you will need to show due diligence that you have the ability for an appropriate and rapid response to detect and deter misconduct that exposes your company to operational risk that may have a material effect on your business. |
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