Virtual currency in sanctioned jurisdictions: stepping outside of SWIFT

2019 ◽  
Vol 20 (2) ◽  
pp. 39-44 ◽  
Author(s):  
Katherine Kirkpatrick ◽  
Christine Savage ◽  
Russell Johnston ◽  
Matthew Hanson
Keyword(s):  
Best Practices ◽  
Design Methodology ◽  
Virtual Currency ◽  
Content Type ◽  
The Us ◽  
Expert Analysis ◽  
Practical Implications ◽  
Foreign Assets

Purpose To understand and analyze sanctions evasion and enforcement via virtual currencies. Design/methodology/approach Discusses various jurisdictions’ attempts to further the use of virtual currency to facilitate and maximize access to international funds; analyzes the aspects that make virtual currency uniquely suited to evade sanctions; suggests best practices for industry participants to be sure to account for the differences in crypto asset structure and related risks. Findings The US Treasury Department’s Office of Foreign Assets Control (OFAC) has explicitly stated that despite virtual currency’s anonymity, industry participants are still responsible for policing and enforcing client compliance. Although sanctioned jurisdictions are thinking creatively about ways around SWIFT, the use of virtual currency to skirt sanctions presents certain challenges. Practical implications Virtual currency industry participants should understand OFAC’s specific guidance regarding compliance obligations in the cryptocurrency space, and should implement best practices and conservative measures to avoid unknowingly running afoul of sanctions laws. Originality/value Expert analysis and guidance from experienced investigations and sanctions lawyers.

2020 SEC risk alert provides guidance for private fund advisers

2020 ◽  
Vol 21 (1) ◽  
pp. 49-54
Author(s):  
Kenneth Breen ◽  
Phara Guberman
Keyword(s):  
Best Practices ◽  
Design Methodology ◽  
Conflicts Of Interest ◽  
Securities And Exchange Commission ◽  
Internal Controls ◽  
Content Type ◽  
Policies And Procedures ◽  
Expert Analysis ◽  
Practical Implications ◽  
The U.S

Purpose To analyze the U.S. Securities and Exchange Commission (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) June 2020 Risk Alert, which identified three categories of deficiencies that the SEC regularly finds in its reviews of advisers to private funds, in order to understand its guidance and recommend best practices. Design/methodology/approach The study discusses the categories of deficiencies that the SEC regularly finds in its reviews of private fund advisers, current SEC enforcement trends, and recommendations for disclosures, internal controls, policies and procedures. Findings The SEC will expect private funds to identify and remedy regular deficiencies in three primary categories: gaps in client and investor disclosures regarding conflicts of interest; deficiencies in disclosures related to fees and expenses; and issues with policies and procedures regarding the treatment of material nonpublic information. Practical implications Private fund advisers should expect increased scrutiny during examinations on the identified deficiencies and use this opportunity to be proactive in addressing these issues. Originality/value Expert analysis and guidance from experienced securities enforcement attorneys.

OCIE issues risk alert on the most frequently identified advisory fee and expense compliance issues

2018 ◽  
Vol 19 (4) ◽  
pp. 1-3
Author(s):  
Robert Van Grover
Keyword(s):  
Design Methodology ◽  
Best Practice ◽  
Investment Management ◽  
Content Type ◽  
Informed Decisions ◽  
Policies And Procedures ◽  
The Us ◽  
Investment Advisers ◽  
Practical Implications

Purpose To summarize and interpret a Risk Alert issued on April 12, 2018 by the US SEC’s Office of Compliance Inspections and Examinations (OCIE) on the most frequent advisory fee and expense compliance issues identified in recent examinations of investment advisers. Design/methodology/approach Summarizes deficiencies identified by the OCIE staff pertaining to advisory fees and expenses in the following categories: fee billing based on incorrect account valuations, billing fees in advance or with improper frequency, applying incorrect fee rates, omitting rebates and applying discounts incorrectly, disclosure issues involving advisory fees, and adviser expense misallocations. Findings In the Risk Alert, OCIE staff emphasized the importance of disclosures regarding advisory fees and expenses to the ability of clients to make informed decisions, including whether or not to engage or retain an adviser. Practical implications In light of the issues identified in the Risk Alert, advisers should assess the accuracy of disclosures and adequacy of policies and procedures regarding advisory fee billing and expenses. As a matter of best practice, advisers should implement periodic forensic reviews of billing practices to identify and correct issues relating to fee billing and expenses. Originality/value Expert guidance from experienced investment management lawyer.

FINRA’s disciplinary actions in 2017: increased restitution ordered with minimal changes in number of cases

2018 ◽  
Vol 19 (2) ◽  
pp. 19-23
Author(s):  
Brian Rubin ◽  
Adam Pollet
Keyword(s):  
Money Laundering ◽  
Design Methodology ◽  
Disciplinary Actions ◽  
Financial Industry ◽  
Electronic Communications ◽  
Content Type ◽  
The Past ◽  
Expert Analysis ◽  
Research Analysts ◽  
Practical Implications

Purpose The purpose of this paper is to analyze the Financial Industry Regulatory Authority’s (FINRA) 2017 disciplinary actions, the issues that resulted in the most significant fines and restitution and the emerging enforcement trends from 2017 and beyond. Design/methodology/approach The approach of this paper discusses the disciplinary actions in 2017 and prior years, details the top 2017 enforcement issues measured by total fines assessed, including anti-money laundering, trade reporting, electronic communications, books and records, research analysts and research reports, and explains current enforcement trends, including restitution, suitability cases and technological issues. Findings In 2017, restitution more than doubled from the prior year, resulting in the fourth highest total sanctions (fines combined with restitution and disgorgement) assessed by FINRA over the past 10 years. Practical implications Firms and their representatives should heed the trends in both the substantial restitution FINRA is ordering and the related enforcement issues in the cases FINRA has brought. Originality/value This paper provides expert analysis and guidance from experienced securities enforcement lawyers.

Understanding a shifting methodology

2018 ◽  
Vol 30 (11) ◽  
pp. 3423-3441 ◽  
Author(s):  
Elizabeth A. Whalen
Keyword(s):  
Best Practices ◽  
Online Community ◽  
Design Methodology ◽  
Virtual Communities ◽  
Tourism Research ◽  
Content Type ◽  
Analysis Techniques ◽  
Hospitality And Tourism ◽  
Qualitative Methodologies ◽  
Practical Implications

PurposeWhile netnography was established to study virtual communities from the traditional ethnography methodology, over time it has evolved and moved away from standard ethnographic practices. The modifications are especially prevalent in hospitality and tourism research because of the nature of experiential and service-based goods. This gap has created exciting new opportunities for researchers. As netnography has matured into its own methodology, it has provided the opportunity for researchers to use netnography techniques or more traditional techniques by following ethnography methodologies. This paper aims to analyze the differences between these two methodologies within hospitality and tourism literature enabling researchers to choose the methodology that is most suited for their project.Design/methodology/approachThis study reviews netnographic research in hospitality and tourism and compares current uses of netnography against traditional ethnographic methodologies.FindingsThere are four major differentiating points between netnography and ethnography: online community definitions, data collection methodologies, ethics in research and data analysis techniques.Practical implicationsIn comparing ethnography and netnography in hospitality and tourism research, this analysis provides a foundation to evaluate the best use and best practices for these two distinct qualitative methodologies in the field. The study also provides references to how other hospitality and tourism researchers have used netnography.Originality/valueEthnographic principles grounded in the foundation of anthropological doctrines are important and distinct from netnography. The ability to use the diverse tools in the qualitative methods toolbox will help hospitality and tourism researchers understand the transforming marketplace.

HR’s new role: rethinking and enabling digital engagement

2017 ◽  
Vol 16 (2) ◽  
pp. 60-65 ◽  
Author(s):  
Ravin Jesuthasan
Keyword(s):  
Best Practices ◽  
Digital Technology ◽  
Design Methodology ◽  
Industrial Revolution ◽  
Digital Technologies ◽  
Content Type ◽  
Future Of Work ◽  
The Future ◽  
Digital Engagement ◽  
Practical Implications

Purpose This paper aims to explore how a new industrial revolution with digital technology at its core is disrupting the workplace. It shares how HR has an opportunity to use data and digital technologies to reinvent how organizations engage with their workforce. It answers the question of how HR pivots from its legacy focus on compliance and being a steward of employment to the work and helping the organization strengthen its connection with its workers through improved digital engagement. Design/methodology/approach The paper is based on Willis Towers Watson thought leadership and references recent findings from their research. Findings The paper explores how digital technologies have changed how workers connect with their co-workers and the organization. In addition, it examines how digital technologies are changing how work gets done. Research limitations/implications The paper is not exclusively based on research. Practical implications The paper explores how digital technologies drive engagement, HR’s role as steward of the work and enabler of digital engagement and best practices for enabling digital engagement in the modern workplace. Originality/value This paper fulfills a need to assist HR leaders in thinking through the implications of the future of work and how digital technologies will shape that future.

Library graphic design best practices and approval processes

2016 ◽  
Vol 117 (1/2) ◽  
pp. 63-73 ◽  
Author(s):  
Diana K Wakimoto
Keyword(s):  
Best Practices ◽  
Graphic Design ◽  
Design Methodology ◽  
Best Practice ◽  
Library Science ◽  
Science Literature ◽  
Design Processes ◽  
Content Type ◽  
Qualitative Survey ◽  
Practical Implications

Purpose – The purpose of this paper is to explore graphic design best practices and approval processes used by librarians. Design/methodology/approach – This paper used an online, qualitative survey to collect data on librarians’ design processes and best practices. The responses were reviewed to determine categories and themes of librarians’ design processes and best practices to gain an understanding of the state of graphic design in libraries. Findings – The majority of the respondents reported that there were no formal guidelines, design committees or approval processes at their libraries. While some librarians were aware of and used graphic design best practices, many respondents were unsure of what constituted a best practice in graphic design. Research limitations/implications – The paper was exploratory and the respondents cannot be said to be representative of all librarians and, therefore, generalizations to all librarians are not possible. Practical implications – Findings may help librarians who assume design duties in their libraries in exploring best practices and discussing design approval processes. Originality/value – This paper is one of the few papers in the library science literature on graphic design as applied specifically to librarians. It increases our understanding of graphic design in libraries.

Methodological lapses in plant and equipment valuation amongst Lagos valuers

2019 ◽  
Vol 37 (4) ◽  
pp. 529-546
Author(s):  
Austin Chike Otegbulu
Keyword(s):  
Content Analysis ◽  
Best Practices ◽  
Design Methodology ◽  
Content Type ◽  
Potential Sources ◽  
Valuation Process ◽  
Practical Implications ◽  
Structured Questionnaire

Purpose The purpose of this paper is to investigate the level of discrepancy in the valuation process adopted by valuers in the study area with a view to provide solution. Design/methodology/approach The study is based on both structured questionnaire and content analysis of valuation reports. In total, 185 (41 percent) structured questionnaires were randomly distributed to practicing estate surveying firms; out of 450 firms in Lagos, 173 were retrieved and used for analysis. However, the content analysis was based on 54 valuation reports on plants and equipment to investigate the extent of compliance to valuation process, standard and best practices among practitioners. Findings The findings from the study show that most of the practitioners lack the expertise to carry out plant and machinery (P&M) valuation, and there is evidence of poor application of methodology and lack of adherence to standards. Practical implications The findings from this study will reinforce the need for specialization and enforcement of standard in plant and equipment valuation practice, which will enthrone consistency, uniformity and reliability. Originality/value This study is the first to deal with methodology lapses in plant and equipment valuation in the study area. Ashaolu (2016) worked on the inter-disciplinary nature of plant and equipment valuation, whereas Otegbulu and Babawale (2011) worked on valuer’s perception or potential sources of inaccuracy in P&M valuation in Nigeria.

Popular reporting: learning from the US experience

2019 ◽  
Vol 32 (1) ◽  
pp. 92-113 ◽  
Author(s):  
Francesca Manes-Rossi ◽  
Natalia Aversano ◽  
Paolo Tartaglia Polcini
Keyword(s):  
Content Analysis ◽  
Best Practices ◽  
Local Governments ◽  
Legitimacy Theory ◽  
Content Type ◽  
The Us ◽  
The Usa ◽  
The City ◽  
Qualitative Characteristics ◽  
Practical Implications

Purpose The purpose of this paper is to explore a citizen-centered tool for public accountability, the popular report (PR). Elaborating on previous studies and on content analysis of a sample of municipalities in the USA, this paper aims to identify the qualitative characteristics and content elements that PR should have to serve as a legitimation tool. Design/methodology/approach The study adopts a mixed methodology. After the analysis of previous studies on PR and best practices in US municipalities, a list of content elements and qualitative characteristics of PR is compared with results emerging from the content analysis of PR published by of a sample of municipalities in the USA. Findings The analysis reveals that the PR should embed information about the government’s sources of revenues and taxes, expenditures, cost of government services, liveability and governance of the city. Research limitations/implications The paper offers new knowledge on reporting centered on citizens, framing the analysis in the legitimacy theory. Even though the research relates only to the US context, the results may assist standard setters in preparing guidelines for local governments to communicate financial data to citizens and stimulate further research in other contexts. Practical implications The results may encourage local governments to prepare a PR suitable to discharge accountability and gain legitimation. Originality/value This study is the first to discuss the PR within a theoretical framework, in this case, legitimacy theory. Moreover, a further novelty lays in the analysis carried out on the PRs published by US municipalities in order to derive qualitative characteristics and content elements with which the PR should comply.

Parties push to enforce statutory time limits on SEC enforcement actions

2015 ◽  
Vol 16 (3) ◽  
pp. 30-32
Author(s):  
Benjamin Neaderland ◽  
Jared Cohen
Keyword(s):  
Design Methodology ◽  
District Of Columbia ◽  
Securities And Exchange Commission ◽  
Courts Of Appeals ◽  
Content Type ◽  
Time Limits ◽  
Court Of Appeals ◽  
Securities Law ◽  
The Us ◽  
Practical Implications

Purpose – To alert companies and individuals subject to regulation and investigation by the US Securities and Exchange Commission (SEC) of potential arguments to enforce time limits on enforcement actions that have heretofore commonly been ignored. Design/methodology/approach – Analyzes two cases - one recently decided and one pending - in US Courts of Appeals, explains significance of issues at stake. Findings – The Courts of Appeals for District of Columbia Circuit has recently reviewed, and the Court of Appeals for the 11th Circuit will soon decide whether statutory timing provisions effectively remove SEC power to bring enforcement actions past their deadlines, at least in some circumstances. Practical implications – Depending on the outcomes of the cases, companies and individuals may gain a new procedural defense or two against SEC enforcement actions. They may also expect the SEC to respond by more actively seeking tolling agreements, and/or being more cautious in issuing Wells notices. Originality/value – Guidance based on pending decisions interpreting US securities law, may bring regulatory adjustments to agency practice and procedure.

David’s view of Goliath in open innovation

2017 ◽  
Vol 33 (4) ◽  
pp. 1-3
Keyword(s):  
Open Innovation ◽  
Design Methodology ◽  
Open Spaces ◽  
Content Type ◽  
Start Up ◽  
The Us ◽  
Pertinent Information ◽  
Stereotypical Image ◽  
Practical Implications ◽  
Super Cool

Purpose This paper aims to review the latest management developments across the globe and pinpoint practical implications from cutting-edge research and case studies. Design/methodology/approach This briefing is prepared by an independent writer who adds their own impartial comments and places the articles in context. Findings The stereotypical image of a new start-up has probably been driven either by pictures in Wired magazine – where they are super-cool, achingly on-trend lofts with huge open spaces and juicing machines – or by the US sitcom Silicon Valley where young men are sat in some guy’s kitchen fighting over the least rancid mug for a cup of instant coffee. There is a happy medium, and it is a very large place as almost no start-up is like this, and they are like almost everything else. They are probably like the very office you work in every single day. Practical implications The paper provides strategic insights and practical thinking that have influenced some of the world’s leading organizations. Originality/value The briefing saves busy executives and researchers hours of reading time by selecting only the very best, most pertinent information and presenting it in a condensed and easy-to-digest format.

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