Senior Member of "The Seven Samurai" Hedge Fund | Compliance Procedures and Responsibilities

Compliance Procedures and Responsibilities

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Meriam Mastrani is a senior member of "The Seven Samurai," a high-flying hedge fund. Meriam supervises a group of 6 portfolio managers and is also involved in advising some independent clients. To prevent violations of securities laws at the firm, Meriam has instituted some standard procedures in conjunction with the

Compliance Department. However, for the past 6 months, he has been extremely busy catering to his clients to be able to check on the weekly compliance reports. Meriam does not have a deputy whom he can delegate his duties to. No violations of any laws have been detected at The Seven Samurai. Meriam has

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Standard III (E) - Responsibilities of Supervisors - requires that supervisors must take reasonable care to ensure that their subordinates do not violate any laws or the code of conduct. This includes designing effective procedures to deter fraudulent activity. However, merely enacting such procedures does not fulfill the member's duties. If steps are not taken to make sure that the restrictions are being abided by, the member could be deemed in violation of Standard III (E). By not keeping track of the activities of his subordinates for an extended period of time and not having a deputy to whom such a duty could be delegated, Meriam has violated Standard III (E).