Case study – Governance and conflicts of interest review

Our client was a boutique investment firm that conducts both asset management and corporate finance services.  Our review, conducted at the Firm’s request focused on the adequacy and effectiveness of its corporate governance arrangements, including decision making processes in relation to the Firm’s structured corporate finance transactions, including those relating to a key shareholder, connected associates and related business interests. The review covered corporate governance arrangements, decision making arrangements, adequacy of systems and controls, conflicts of interest management, compliance, Know Your Client, Anti-Money Laundering arrangements as well as a detail review of each of the transactions under review.

We agreed with the client the documentation it would provide and requested further documentation during the course of our review, including the client’s compliance manual and related compliance documentation, e-mail and other correspondence for the relevant period and all documents related to specified transactions.  Our work comprised a detailed review of the documents and focused interviews with senior management.  We sought to corroborate management representations with documentation.  Our findings were documented in a detailed report which was structured to address the scope document.  We agreed our findings and recommendation with the client and included their responses to our recommendations.  We provided a critical opinion on the client’s compliance arrangements taking into account anti-money laundering controls and conflicts of interest, considering the scope for and any evidence of bribery and corruption.

Cordium works with many hundreds of smaller investment firms annually to support their compliance arrangements.  We are highly expert in the regulatory requirements of these investment firms and we have deep experience of assisting them to demonstrate compliance with the UK regulatory requirements.