Messaging App Enforcement and Internal Controls

The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent SEC and CFTC enforcement actions around messaging app non-compliance.

Join Tom and Matt as they take a deep dive into the enforcement actions and then consider how such claims would impact non-regulated industries. Regulated industries, particularly broker-dealer firms like Wells Fargo and Morgan Stanley, are facing enforcement actions and hefty fines for their employees' use of messaging apps like WhatsApp and Snapchat that allow record preservation to be disabled. The involvement of senior managers in these misconducts has prompted the SEC to require an independent compliance consultant in settlements.

The conversation between Tom and Matt emphasizes the importance of messaging policies and procedures in regulated industries and the need for stricter compliance measures. They also discuss the complexities and potential consequences of record-keeping obligations and the regulatory concerns over the use of messaging apps. The conversation briefly touches on the future of AI chatbots in customer service, with differing perspectives on their ethical implications. Overall, the conversation highlights the significance of messaging policies, enforcement, and compliance in regulated industries.

Key Highlights

·      Enforcement Actions Against Regulated Industries

·      Enforcement actions and messaging policies

·      Record-keeping obligations for broker dealers and other industries

·      Regulatory concerns over the use of messaging apps

·      Internal Controls and non-regulated industries

 Resources

Matt 

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Blog Post in Radical Compliance

No Smoke and No Fire: The Rise of Internal Controls Absent Anti-Bribery Violations in FCPA Enforcement by Karen Woody in Cardoza Law Review

Tom 

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