In Journal of Investment Compliance Article, Anne-Marie Godfrey Discusses Hong Kong SFC Circular on Asset Management Industry

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Journal of Investment Compliance has published the article “Hong Kong Securities and Futures Commission (SFC) highlights operating, control and compliance deficiencies in asset management industry,” written by Akin Gump investment management partner Anne-Marie Godfrey.
In the article, Godfrey examines the nine common areas of noncompliance in managing investment funds and discretionary accounts that were detailed by the Hong Kong Securities and Futures Commission (SFC) in a circular last September. She finds that these instances “provide a useful insight into key ‘problem areas’ that are of particular concern to the SFC.” Among them:
- inappropriate receipt of cash rebates giving rise to apparent conflicts of interest
- deficiencies in systems and controls for ensuring best execution
- failure to safeguard fair order allocation
The article suggests that “all SFC-licensed asset managers would be well advised to revisit their internal governance structures and operational policies and procedures in order to ensure that these are compliant with applicable standards and requirements.” In addition, Godfrey points out that the SFC “is a vigilant regulator and carefully monitors asset managers in order to ensure compliance” with various regulatory bodies.
To read the full article, which originated as an Akin Gump client alert, please click here.