What is your company's new year's resolution?
Since it is the beginning of the year, it is timely to check whether your company's compliance plan needs to be updated or enhanced. If you do not have a compliance plan at all yet, perhaps this may be a good time to get one. Annual compliance plans vary enormously in content and degree of detail from company to company but at a minimum we usually advise clients to ensure that they cover (i) compliance manual / internal procedure reviews / updates, (ii) business plan reviews / updates, (iii) assessment of any business initiatives on the horizon to see whether they will require regulatory approval / notification, (iv) compliance training, and (v) compliance monitoring (including for those companies with the resources, a detailed review of a specific business operation). It is important that all such actions are documented so that the company can demonstrate that the plan has been executed.
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