An Analysis of Supervision Cases Involving Outside Business Activities
ROBERT M. ROMANO
(Litigation partner in the New York office of Latham & Watkins. He specializes in the defense of Securities and Exchange Commission and other financial investigations.)
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Abstract
Supervising an employee even under ordinary circumstances is no easy task. What happens when some or all of an employee's activities occur outside the firm? This article explores several recent enforcement cases in which a manager or firm has been held responsible (or at least criticized) for failing to supervise a broker where the conduct in question took place outside the firm. It also suggests the minimum procedures that supervisors should follow in such cases.
Citation
ROMANO, R.M. (2000), "An Analysis of Supervision Cases Involving Outside Business Activities", Journal of Investment Compliance, Vol. 1 No. 1, pp. 55-58. https://doi.org/10.1108/eb045871
Publisher
:MCB UP Ltd
Copyright © 2000, MCB UP Limited