Sfc internal control guidelines *308*

The MIC regime has heralded a re-emergence of focus on the Internal Control Guidelines - it is very clear that when drafting the MIC circular, the SFC referred to the Internal Control Guidelines. We have noted over the years that firms tend not to focus on the obligations in the Internal Control Guidelines as much as the two Codes of Conduct. the Sponsor Guidelines, which set out continuing compliance requirements, including specific competence requirements as well as the responsibilities of management and sponsor principals. Sponsors are also required to maintain proper systems, controls and procedures in accordance with the SFC's Management, Supervision and Internal Control Morgan Stanley Engages Independent Expert after Hong Kong Fine. It has agreed to engage an independent expert to oversee its internal controls in future. SFC's Investigation. no clients' consents were obtained in breach of the internal control guidelines. Its failures to separate agency A Quick Look at the New SFC Guidelines on Disclosure of Inside Information Quick Read A Quick Look at the New SFC Guidelines on Disclosure of Inside Information OBJECTIVE TEST VS. SUBJECTIVE TEST reporting of sensitive matters and internal awareness The SFC considers that Ping An did not have an effective compliance function during the Relevant Period, in breach of Part V of the Internal Control Guidelines and paragraph 12.1, GP2, GP3 and GP7 of the Code of Conduct. SFC compliance and licensing hints. 25 April 2017 the SFC reprimanded and fined a licensed company HK$2 million for regulatory breaches and internal control failures. The Statement of Disciplinary Action has some useful pointers on what is the SFC's expectation of adequate internal The Internal Control Guidelines state that a licensed corporation should establish, document and maintain an effective management and organisational structure. The SFC thus requires the Board to approve a formal document setting out the licensed corporatio