Compliance Monitor
Conflicts of interest and other supervisory priorities for wholesale firms
The regulator has published feedback on its multi-firm reviews into share buybacks, gifts and entertainment, off-channel communications, transaction governance, along with client asset arrangements. Denis O'Connor discusses discrepancies and lessons from the findings.
Denis O'Connor is a fellow of both the Institute of Chartered Accountants in England & Wales and the Chartered Institute of Securities and Investment. He was a member of the British Bankers' Association Money Laundering Committee from 2003-10 and a member of the Joint Money Laundering Steering Group's board and editorial panel between 2010 and 2016. He has been a frequent speaker at industry conferences on financial crime issues, both in the United Kingdom and abroad.

All firms may learn lessons from the recently published Review [1] by the Financial Conduct Authority of some wholesale firms'
management of certain perennial regulatory issues. The Review provides an opportunity for firms to benchmark their own procedures
and reveals data along with insights that are not usually publicly available.