Top Level Corporation Limited

TopLevel Case Study

Chinese Wall

Prevent illegitimated data exchange and conflict of interest. Effective checks and balances.

The Background

In the heyday of "dot-com" era, the improper exchange of sensitive information between employees of the brokering department and the corporate-advisory department were rampant. After some scandals related to publication of dishonest positive research analyses in favor of the investment banking department, the US government has since passed laws strengthening the Chinese wall such as Title V of the Sarbanes-Oxley Act in order to prevent such conflicts of interest.

ur client is a multi-national finance company serving numerous investors. Any accidental or malicious exchange of sensitive information between the Research and Sales departments may lead to legal proceedings from both the government and their customers, as well as financial loss and PR catastrophe. It is necessary for them to take stringent, preventive measures against potential conflict of interest for best business practice and legal compliance.

The Needs

To ensure a level playing field for all customers, our client was determined to separate the Research department from the Analysis and Sales department.

The client looked for ways to:

Block email exchange between the Research department and the Analysis and Sales department in order to:

Prevent leakage of corporate insider information, which could influence the clients' investment decisions
Prevent staff to take advantage of facts that are not yet known to the general public

Enforce compliance for on-going control

The Solution

After studying their needs, we implemented a solution with TrustSafe® Email Compliance Manager, including the Mail Blockage and Mail Channel modules to ensure the compliance:

✓ Deploy Mail Blockage to:

Erect a virtual Chinese wall separate and isolate the Research department from the Analysis and Sale Department to prevent conflict of interest
Auto check for non-compliant email transmission
Auto block illegitimate email and pending for review
Alert specific manager for further handling

✓ Deploy Mail Channel to:

Blind copying of emails from the Research department to the management
Auto forwarding emails of untrusted employees to the management
Secretly monitor untrusted employees without alert the targets or changing the setting of existing email system

✓ Keep good track and control of the flow confidential data before it's too late

Effective Email Handling

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