Expertise

Risk Management & Compliance

Superior Guidance to Navigate Challenges

Identifying and navigating risks facing financial service industry companies require keen judgment, experience, and expertise. Patomak Global Partners have deep experience and first-hand knowledge as former senior leaders of federal agencies supervising the nation’s markets, banks, and financial services industry.

Whether turning to Patomak to help assess risk of new markets or products or to audit compliance in advance of regulatory scrutiny, senior executives trust the Patomak team to help guide them through complex challenges and make the most of business opportunities.

Regulatory licensing

Patomak Global Partners assist firms in designing and implementing compliance frameworks for regulatory licensing to help ensure the approval process and consummation goes smoothly. To support these efforts, the team develops policies, procedures, and internal controls for trading, risk management, margin, capital, compliance, cyber security, anti-money laundering and know-your-customer requirements, community reinvestment and consumer compliance, and other functions considered during the licensing process.

Risk management, trading and surveillance, swap data reporting, and capital adequacy assessments

The Patomak team assesses the design and implementation of risk management, trading and surveillance, and reporting (SDR, CAT, TRACE) systems to ensure they meet regulatory requirements. Team members also review capital frameworks and regulatory capital modeling approaches to ensure clients exceed regulatory expectations.

Governance and supervision

Patomak reviews governance frameworks and advises clients regarding shareholder relations, management duties and responsibilities, and committee structures and charters.

Compliance program assessment and exam preparation

Patomak Global Partners assess compliance programs at banks, broker-dealers, swap dealers, security-based swap dealers, futures commission merchants, consumer lenders, mortgage servicers, digital asset trading platforms, fintechs, and other financial firms to identify control weaknesses. The team provides recommendations to remediate identified issues and conducts follow-up to ensure successful remediation.

The team works with executives to prepare clients for examinations by U.S. banking regulators, the Consumer Financial Protection Bureau (CFPB), the Commodity Futures Trading Commission (CFTC), the Financial Crimes Enforcement Network (FinCEN), the Financial Industry Regulatory Association (FINRA), the National Futures Association (NFA), the Securities and Exchange Commission (SEC), and other authorities.

Representative Engagements

Examples of the Patomak Global Partners’ risk management and compliance engagement include:

Compliance and Examinations

Served as an independent compliance consultant for a broker-dealer pursuant to an SEC order focusing on controls and procedures regarding the Rules 15c3-1 (Net Capital) and15c3-3 (Customer Protection)
Conducted for a large financial institution with multiple broker-dealers first an independent review and, thereafter, annual reviews to support chief executive certification regarding SEC Rule 15c3-5 (Market Access Rule) compliance, including financial, regulatory, and other risk management controls and supervisory procedures
Analyzed swap data repository reporting for a large global swap dealer, assessing compliance with CFTC Parts 43 and 45 regulations
Served as an independent compliance consultant pursuant to FINRA enforcement actions regarding a broker-dealer’s compliance with blue sheets and TRACE reporting
Advised a corporate issuer on responding to globally coordinated enforcement actions related to the manipulation of commodities and securities markets
Advised a large U.S. fintech company on compliance considerations regarding new product offerings and business expansions in Hong Kong and Singapore

Governance and Supervision

Served as an implementation partner for a leading cryptocurrency institutional brokerage on CFTC and NFA registration and end-to-end implementation of a compliance and risk management program spanning trade surveillance, margin, capital reporting, and client onboarding
Conducted an independent and holistic review, analysis, and assessment of policies and procedures related to governance and clearing activities at a major clearinghouse
Examined and recommended enhancements to proprietary alternative trading systems
Engaged in a detailed review, analysis, and assessment of a major hedge fund’s policies, procedures, systems, and controls designed to prevent the misuse of material non-public information by its employees and to prevent the occurrence of insider trading
Analyzed risks and controls related to business processes at a major consumer lender to ensure compliance with CFPB regulations and identified deficiencies
Developed processes at a large banking group to stand up a Customer Identification Program and “Know Your Customer” programs to comply with FinCEN requirements
Consulted with public companies, clearinghouses, and exchanges regarding corporate governance
Developed policies and procedures, trained staff, conducted internal reviews, and managed annual employee certification on Foreign Corrupt Practices Act requirements
Assessed compliance with CFTC regulations covering policies, procedures, and controls for a major swap dealer, focusing on supervision, business conduct standards, clearing and execution, and large trader reporting

Regulatory Licensing

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