‘Heed This Message’: Organizations That Fail to Contemplate Off-Channel Communications ‘Do So at Their Own Peril’
Discovery Advocate
AUGUST 11, 2023
In addition to agreeing to pay the fines, the firms committed to improving their compliance mechanisms to prevent such violations in the future. Even if company policies forbade such off-channel communications, the firms were nevertheless culpable for “failing to reasonably supervise with a view to preventing and detecting those violations.”
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