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Compliance

ComplianceTalking Shop
September 29, 2022

Talking Shop: Third Parties for SWIFT Attestation Compliance?

Editor’s note: NeuGroup’s online communities provide members a forum to pose questions and give answers. Talking Shop shares valuable insights from these exchanges, anonymously. Send us your responses: [email protected] Member question: “Are any of you SWIFT corporate members? If yes, SWIFT requires an independent assessment of controls as part of their security attestation compliance that can be done by internal audit (IA) or a third party. Which third-party vendors do you use?” Peer answer 1: “We are using PwC to perform the independent assessment. We have…
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ComplianceCryptoTechnology
July 28, 2022

KYC: Know Your Crypto

Conversations with members reflect a need to screen for sanctioned accounts and illicit activity. Here are some options. With no end in sight to the war in Ukraine and sanctions on Russia, corporates eyeing cryptocurrency opportunities are asking pressing questions about screening and investigating counterparties in transactions involving crypto. At a recent meeting of NeuGroup’s digital assets working group, one member expressed concerns that an NFT his company had sold could be resold to someone in Russia, with a portion of…
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BankingComplianceRegional
April 14, 2022

Adding a Sanctions Checklist to a Crisis Management Playbook

Treasurers navigating the twists and turns of the deepening crisis in Ukraine took time out to hear about some best practices in crisis management.Editor’s Note: NeuGroup is running weekly special sessions on the Russian-Ukrainian crisis. Senior executive advisor Paul Dalle Molle, a former banker with extensive European experience, leads the discussions.By Paul Dalle Molle Financial fallout from Russia’s invasion of Ukraine has put new focus on how multinational corporations plan for and manage geopolitical crises. And while all big companies devote…
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Capital MarketsCompliance
January 26, 2022

SEC Share Repurchase Proposals: Key Takeaways From a Special NeuGroup Session With Sidley Austin

Treasury teams seek guidance on how best to respond to SEC’s buyback disclosure and cooling-off period proposals. In response to requests from several members, NeuGroup recently hosted a special session with partners from the law firm Sidley Austin to discuss proposed rule amendments to SEC Rule 10b5-1 and disclosures about share repurchase plans that the SEC announced in mid-December. The session followed one on the same topic NeuGroup held the week before. Prabhat Mehta and Sonia Gupta Barros, partners in…
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ComplianceRisk Management
January 26, 2022

Drawing Legal Lines: Internal Audit and Attorney-Client Privilege

Insights on when and how internal auditors involve lawyers to protect information in an audit report.Most members of NeuGroup for Internal Audit Executives either don’t have a formal process to secure attorney-client privilege (ACP) for their audit reports or are working to formalize one. That takeaway emerged at a recent group session where other members shared how the process works at their companies. But first, some context: According to the law firm Gibson Dunn, “Generally speaking, internal audit reports and…
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Capital MarketsCash & Working CapitalCompliance
January 12, 2022

Talk About SEC’s Proposed 30-Day Buyback Cooling-Off Period Heats Up

Members say the proposal for 10b5-1 plans would limit a corporate’s flexibility to execute buybacks efficiently.The SEC’s proposal that corporates wait 30 days after the adoption of a Rule 10b5-1 share repurchase plan before buying back stock would significantly restrict the flexibility of companies to execute the plans effectively. That key takeaway emerged at a session NeuGroup convened this week at the request of treasurers examining the potential implications of several SEC proposals issued Dec. 15 regarding 10b5-1 plans, including…
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ComplianceTalking ShopTechnology
January 3, 2022

Talking Shop: Use a TMS for Audit and Confirmation of Bank Accounts?

Editor’s note: NeuGroup’s online communities provide members a forum to pose questions and give answers. Talking Shop shares valuable insights from these exchanges, anonymously. Send us your responses: [email protected] Member question: “Has anyone had success using their TMS for audit and confirmation of bank accounts? We are in the midst of our annual audit process. We have a number of accounts confirmed by Confirmation and the remaining have to be confirmed by treasury providing bank statements from bank portals. “We are…
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Capital MarketsComplianceESG
December 15, 2021

Treasury’s ESG Angst Over Auditors and Credit Rating Agencies

Upper management wants ESG audits to be merged with overall financial audit, to some members’ dismay.Assistant treasurers (ATs) mulling renewals of their companies’ revolving credit lines next year compared notes in a recent meeting session on ESG-related issues, as those factors increasingly play a role in credit decisions—even if it’s unclear precisely how. One concern: There’s a push to merge ESG-related auditing with the overall financial auditing typically done by a Big Four accounting firm, a move the ATs frowned…
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Capital MarketsCash InvestmentsCompliance
December 8, 2021

Pain You Can Manage and Pain You Can’t: Separately Managed Accounts

SMAs mean accepting KYC and legal dept. pain, but clear communication can save plenty of heartache with managers. Members joined forces for a panel discussion on the pain points associated with setting up, maintaining and reporting for separately managed accounts (SMAs) at a recent meeting of NeuGroup for Cash Investment. Not surprisingly, the most painful parts are the know-your-customer (KYC) obligations and the legal agreement tug-of-war needed for account setup. The encouraging, somewhat unexpected takeaway: Effective communication and a strong relationship…
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BankingCompliance
October 7, 2021

A Treasury Dream Coming True: Handing KYC to Corporate Governance 

One treasury team made a winning case that the governance group should own KYC.Call it reaching the treasury promised land or a dream come true. Whatever you call it, one treasury team’s early-stage success at shifting responsibility for know your customer (KYC) compliance to a corporate governance group generated plenty of buzz and some envy at a recent meeting of NeuGroup for Global Cash and Banking. “I’m really excited to get out of the KYC business,” the member told his peers…
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