"Prevent and Detect Violations"

9/1/15: The US Securities and Exchange Commission recently settled charges with Citigroup Global Markets saying the company failed to adopt and apply procedures that would prevent and detect transactions signaling the potential misuse of material, nonpublic information. The company also failed to adopt...and implement similar policies and procedures for transactions conducted by an affiliate. While the case focused specifically on federal securities law, it highlights the importance for companies to develop, implement and manage policies and procedures to detect and prevent violations before they become long-term systemic problems. That heads-up applies to all companies, regardless of industry.