Risk and Compliance (RCOM)

A good reputation years in the making can be lost in moments. Managing risk is critical to protecting and preserving a company’s reputation, and compliance with applicable laws and regulations is an essential part of the process. This is one reason why public and private companies, large banks, private equity firms, hedge funds, broker-dealers, mutual funds, and community banks invest in compliance. Venable's RCOM practice is a reliable partner in this endeavor.

We Know Risk Management

Proper implementation, monitoring, and maintenance of an enterprise Risk Management Program should be an annual exercise involving all departments, functions, and key personnel within a business. Relevant practices must be tailored to satisfy business needs and applicable regulatory requirements to properly guide senior management and operational leaders in critical decision-making.

The Venable Risk and Compliance (RCOM) team knows what is at stake. Our practice is directed by professionals experienced in complex regulatory matters, and includes subject matter experts, former regulators, general counsel, and compliance officers who are familiar with the highest levels of regulatory scrutiny. Our attorneys have prepared and implemented Risk Management Programs at financial and other regulated firms and have successfully managed hundreds of examinations with regulators from most federal and state agencies.

We assist clients in successfully navigating oversight from investors, auditors, and regulators and serve as a continuing resource, advocate, and adviser for senior management. Our practical experience helps manage business growth while mitigating risk throughout the firm’s life cycle.

We pride ourselves on our pragmatism, efficiency, and results. We provide honest and succinct assessments of difficult issues and work with clients to implement practical solutions tailored to the structure and culture of a company. Our goal is to establish long-term client relationships, supported by our service and counsel.

We advise clients on the following:

  • Risk Management Program design, implementation, and review
  • Compliance Program design, implementation, and review
  • Targeted review and implementation of policies and procedures
  • Development and implementation of controls and testing programs
  • Mock examinations/gap analysis
  • Examination preparation and on-site examination support
  • Bank Secrecy, AML reviews and assessments, and Office of Foreign Asset Control (OFAC) program development
  • Privacy policy and implementation assessment
  • Information security and data protection assessment
  • Training for in-house teams and boards of directors
  • Enforcement remediation

RCOM for Financial Services Firms

We are committed to protecting the reputations of clients who do business in highly regulated industries, such as financial services. Regular review and testing of a firm’s Risk Management Program ensures proper functioning, compliance with regulatory guidelines, and preparation for oversight from investors, auditors, and regulators. Clients include investment advisers, broker-dealers, large investment banks, community banks, private funds (private equity and hedge funds), and BDCs, to whom we offer the following services: 

Investment Adviser Services
  • Ongoing general counsel and/or chief compliance officer support
  • Policy and procedure review, updates, and development
  • Pre-exam SEC preparation and on-site support
  • Conflict of interest reviews, including personal trading
  • Advertising and marketing materials review
  • Board of directors and senior management training
  • Risk identification, assessment, and program implementation
  • 206(4)-7 review and program implementation
  • SEC mock examinations
  • AML reviews and program implementation
Investment Company Services
  • 38a-1 review and implementation
  • Pre-exam and on-site examination support
  • SEC mock examinations
  • Sub-adviser due diligence program implementation
  • AML reviews and program implementation
Broker-Dealer Services
  • Policies and procedures review and gap analysis
  • Development of 3120 supervisory program
  • Rule 3130 design and reporting
  • Personal trading and conflict review
  • Non-cash compensation review
  • Branch office supervision
Private Fund Services (Private Equity and Hedge Funds)
  • Fees and expenses allocation review
  • Policies and procedures review, updates, and development
  • 206(4)-7 review and program implementation
  • Pre-exam and on-site examination support
  • AML reviews and program implementation
  • Investment committee support
  • Risk management implementation
  • Conflict of interest reviews
Banking Compliance and Risk Management Services
  • Fair lending reviews
  • Consumer Financial Protection Bureau reviews
  • Branch reviews
  • Community Reinvestment Act reviews
  • Regulation 9 review and implementation
  • Full CAMELS review and implementation
  • Dodd-Frank/Volcker Act review
  • Liquidity and stress testing
  • Compliance management system review

Government Experience

Our team is led by two former general counsels and chief compliance officers.