New SEC Division of Enforcement Director Gurbir Grewal urged firms to focus on “proactive compliance” to ensure that they are continually tailoring their compliance strategies to evolving technologies and regulations.
In his first speech as Director, Mr. Grewal cautioned firms against the assumption that if “regulators are particularly focused on issues ‘X’ or ‘Y’ in a given area, that means you or your clients may be able to push the envelope on issue ‘Z’ – or the grey areas around X or Y.” Mr. Grewal said that market participants should “not wait for an enforcement action to put in place appropriate policies and procedures . . . and anticipate these emerging challenges,” highlighting as an example, recordkeeping of off-channel communications, such as those on personal devices and ephemeral apps.
‘Enforcement 40’ for 2020
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