Instructions
This assignment consists of 3r essay questions. The questions are equally weighted in determining your grade. It is a general estimation that each question takes approximately. The exam is open book and there are no restrictions on the materials you may use. Please keep in mind that you are prohibited from discussing or consulting with anyone else in connection with the questions in this exam or your responses or the exam questions until the examination period has ended. 6 pages total. Broken down is 2 pages per essay not including instructions. Approximately 300 words per page.
Essay 1: Memo for Compliance Risk Assessment for Pharma Company
1. A global pharmaceutical company with headquarters in the United States has been investigating claims that staff in China and Lebanon may have bribed doctors. The internal investigation has already uncovered emails indicating that the company’s sales representatives were offering payments and lavish trips to doctors in an effort to get the doctors to prescribe certain of the company’s drugs and vaccines. A recent report in the media noted that bribery scandals could threaten the future of the pharmaceutical companies in emerging markets since wide-ranging probes by the government put companies under scrutiny and can damage their reputations across all markets. The story in the press cites industry critics who have suggested that companies should stop paying outside doctors to promote products, end payments for medical professionals to attend conferences, and detach sales incentives from individual sales targets.
You are the Global Head of Compliance for this pharmaceutical company and have been asked to prepare a memorandum to the CEO outlining your design of a compliance risk assessment that would assist in identifying other locations where the company may have heightened risk of bribery claims. Your assessment is limited to bribery risk. Your memorandum should include how you would assess inherent risk and control effectiveness and then determine residual risk. You should also discuss the metrics and information (both quantitative and qualitative) you would need in conducting this assessment.
Instructions
2 pages: approximately 600 words total
Memo style / Well written English
Structure the memo so that is broken in relevant sections for a compliance risk assessment memo
Make sure that you reference the case in your response
Essay 2: Retail Brokerage Compliance Risk Assessment:
2. You have been asked to conduct a targeted compliance risk assessment of the Retail Brokerage Division at a large wealth management firm known as Ford & Ham, which is headquartered in New York City. Over the past year, Ford & Ham has been experiencing customer complaints associated with certain investment products known as structured products, which were sold to many of its clients by brokers at Ford & Ham. These structured products are more complex than owning shares of a public company or buying a bond or other debt instrument in that the customer’s return is linked in various ways to the performance of an index or other reference rate. These products are generally considered to be suitable for more sophisticated investors with substantial investable assets. Yet, the complaints regarding these products have been received largely from unsophisticated investors with relatively low net-worth profiles.
Your targeted assessment needs to address compliance risk in recommending and selling these structured products to clients. Provide the following information for this targeted risk assessment:
a. Key inherent compliance risks
b. Controls inventory
c. Questionnaire for an interview with the head of the Retail Brokerage Division at Ford & Ham to assess the effectiveness of controls for the selling of suitable investments
Instructions
2 pages: around 600 words
Memo style / Well written English
Structure the memo so that is broken in relevant sections
Make sure that you reference the case in your response
Essay 3: Start up Compliance Risk Assessment:
3. It has been a bad year for HAILO, a start-up ride-sharing company based in New York. Although the company launched its services to much acclaim, HAILO has been plagued with problems from the start. Their smartphone app did not appropriately secure customer information and over 1,000 users had their credit card details stolen. Several of their drivers have been operating their vehicles without a driver’s license and there are ever increasing incidents of cars breaking down, some leading to significant passenger injuries. Complaints to the New York Attorney General about HAILO’s practices and lax standards keep mounting and there is talk about possible criminal charges being brought against the company, its CEO and Board of Directors. HAILO is now considered too risky to use. The CEO knows that he must resuscitate the company’s reputation and re-build customer trust. On the advice of his General Counsel, the CEO decides to hire you as HAILO’s first Compliance Officer.
a. Describe the CEO’s responsibilities to lead the company out of its trouble and foster a culture of compliance.
b. Explain how a Compliance Risk Assessment can prioritize HAILO’s limited resources
