Essential Strategies for Financial Services Compliance, 2nd Edition

Appendix ECompliance Conundrums – What Would You Do?

This appendix consists of examples of the types of situation that occur regularly in the ‘real world’ which might leave you uncertain of how to proceed. Remember that the commentary provided is simply a guide on some of the key issues to consider, some of the most relevant legislative and regulatory provisions (based primarily on the UK environment) and some possible actions that you could take. It is not legal advice and should not be taken as definitive guidance on actions you should take if you ever find yourself in one of the situations described. You should adapt your responses to the specifics of your own firm's activities and customer base, and seek professional legal advice if required.

Conundrums index
Key issues	Dilemma/s
Market abuse/market conduct	1, 4, 5, 6, 7, 8, 9, 10, 11, 13, 16, 17, 18, 26, 27, 32, 45, 46, 50, 51, 55, 58, 59, 60, 65, 68, 74
Client's best interest rule	1, 2, 3, 4, 6, 11, 20, 31, 39, 40, 41, 42, 49, 52, 53, 57, 69, 70, 72
Chinese walls	1, 7, 10, 13, 45, 47, 48, 50, 51, 55, 58, 60, 65
Suitability and appropriateness	2, 3, 4, 39, 40, 42, 57, 69
KYC	3, 15
Churning	4
Inducements	4, 20, 44, 53, 56, 70
Personal account dealing	5, 7, 8, 9, 16, 17, 18, 26, 46, 59, 67, 68, 73, 74
Insider lists	5, 7, 9, 10, 13, 16, 26, 32, 59, 60, 74
Watch and restricted lists	7, 9, 10, 14, 26, 32, 50, 59, 60
Conflicts of interest	10, 13, 14, 18, 19, 20, 21, 30, 44, 45, 47, 48, 53, 55, 56, 57, 58, 70, ...