Editor’s Note: This post includes the written remarks of Commodity Futures Trading Commissioner Caroline D. Pham, prepared and delivered in connection with the NYU Program on Corporate Compliance and Enforcement’s November 14, 2022 Fall Conference.
“If You See Something, Say Something”
NYU Law Program on Corporate Compliance and Enforcement Fall Conference
“If you see something, say something.” These words were a maxim during the nearly seven-and-a-half years that I worked at a bank. It was something that was drilled into the sales and trading teams on the trading floors and in other lines of business, and it was something that Compliance officers repeated in so many trainings and so many refreshers. When in doubt, if you see something, say something. Escalate to your supervisor, your Compliance officer, your Legal coverage, HR, Ethics Office, the anonymous hotline, or other channels—there was no excuse to not escalate.