Chapter 434 Internal Control and Compliance (4416)
Park Avenue Plaza, Manhattan, New York.
Two security guards armed with submachine guns stood at the door of a conference room, while inside the room, a dozen financial elites who usually looked smart and capable were sitting restlessly at the conference table.
And these people would be called out one by one every few minutes or ten minutes.
"Jessica, it's your turn."
A white woman in her thirties pushed open the door of the conference room, poked her head in and shouted.
At the conference table, a professional woman with short brown hair stood up nervously, walked out of the conference room, and, under the guidance of the white woman, walked to another single meeting room a few dozen meters away.
There was a long table in the reception room, with five people sitting opposite the table. Seeing a middle-aged man on the right, the professional woman couldn't help but feel a little nervous.
Compliance Investigations Specialist Donn Scott?
Don Scott is not a direct employee of BlackRock. He previously worked at Forbo for many years and later went to the Ministry of Finance of the United States. He has extensive experience in internal control and compliance.
Because of his background in Fosborne, he led the investigations into many of BlackRock's more difficult internal control and compliance cases.
Why is it Don Scott? What's going on?
Could it be the Cummins case?
The Eurasian woman in the middle should be Jane, the DEI director who has been very popular recently, right?
She was actually sitting in the middle? Could it be that she was leading this investigation?
"Jessica Balaham, please sit down." Don Scott, a white man in his forties or fifties wearing gold-rimmed glasses, pointed at the chair expressionlessly, without even raising his head, and kept flipping through the documents in his hand.
"Jessica Baraham, I'm Internal Control Investigator Don Scott. The four people next to me are colleagues from various departments. Do you know why we're looking for you?"
Don Scott still didn't look up, holding a pen and writing in his notebook.
Jessica Baraham had a forced smile on her face: "Sorry, Tang En, I don't know. I don't think I have done anything that violates internal control and compliance."
Don Scott still didn't look up: "No? Do you still remember the Qianxun private placement case with a scale of 3 billion Malaysian dollars?"
Jessica's heart sank, and she hugged her arms tightly: "I can't remember it clearly, I may need to check the system to remember it."
Don Scott paused for a moment, then raised his head and said, "This case is the largest private placement project of the Alternative Investment Department so far this year. Are you sure you can't remember it now?"
Jessica was nervous, but still shook her head: “I really can’t remember it.”
Don Scott stared at Jessica for a few seconds: "Since you said you can't remember, let me remind you that at 10:37 am on July 15, you passed the department's internal review of this case."
"During your pre-approval process, someone clearly mentioned in the approval opinion that there is no fundamental connection between Qianxun Information Technology Company and Qianxun Network Technology Company."
"According to internal control requirements, the approval process can only continue after the approval initiator clearly clarifies this risk and obtains approval. However, this was not included in your department's approval opinion. Further follow-up on this point ended your approval process. You need to provide a reasonable explanation."
Jessica heaved a sigh of relief upon hearing Don Scott's questioning. "My responsibility is to help the transaction team finalize the approval process. In fact, you should be able to see in the system operation records that I once sent back this approval and asked the transaction team to clarify it again. However, because the case was urgent, I consulted with the higher-ups before concluding my part of the approval work."
Don Scott remained calm: "In other words, your boss, Elijah, has already agreed to the transaction team's review before the previous approval is completed?"
Jessica's heart skipped a beat. Could it be that he was targeting her boss?
"I'm sorry, I can't remember the details."
Jessica shook her head.
For everyone in the workplace, selling out people is the biggest taboo.
"Jessica, integrity is the first principle of BlackRock's internal control and compliance investigations. You have received complete internal control training and should know this."
"I must also inform you that integrity also determines the final investigation results and punishment opinions. Since you are unwilling to cooperate with the investigation, I have nothing else to ask."
Don Enscott closed his notebook with a look of regret, and raised his chin to the thirty-something white woman. "Carol, you can call the next person. The next one is..." Don Enscott looked at the list and said, "Levi Quick, go call him."
Jessica Baraham's heart skipped a beat. Although her butt left the chair, a look of hesitation appeared on her face.
BlackRock’s internal controls and compliance investigations do require employees to act with “integrity.”
But this "integrity" is different from the "integrity" in general human moral values.
Simply put, it means telling the truth to the company.
Even if the company's requirements are "evil" and employees telling the truth will cause harm to others, employees must go against their own values and report the information the company needs truthfully.
This is the "integrity" that BlackRock needs.
Even if you are only aware of the situation but do not report it proactively, you will be charged with "knowing but not reporting" if it is discovered.
Moreover, this kind of "knowing but not reporting" is not the evidence of your "knowing but not reporting", but "reasonable speculation".
To put it bluntly, I think you definitely know it, so that’s what you know.
No evidence is required for company sanctions.
"Wait a moment."
Just as Jessica was about to leave, she saw Jane, who had been sitting in the middle just flipping through the documents without saying a word, suddenly spoke.
"Jessica, are you worried about retaliation afterwards?"
Jiang Nanzhen stared into Jessica Baraham's eyes with her autumn-water eyes, and said softly, "BlackRock strictly prohibits retaliation. You can rest assured that as long as you report the details to the company truthfully, no one will retaliate against you afterwards."
Hearing Jiang Nanzhen say this, Don Scott showed an indifferent look in his eyes.
This woman is really incompetent, what's the point of saying this?
It is said that retaliation is not allowed, but if you offend someone with real power, after a few months when that person is fine, she will be the first one to be held accountable.
Sure enough, Jessica hesitated for a moment: “Thank you, but I think you misunderstood, I really just don’t know anything.”
Jiang Nanzhen tried to persuade her softly a few more times, but Jessica Balaham always insisted that she knew nothing.
Don Scott coughed and was about to speak when he heard Jiang Nanzhen say again: "If you tell me what you know, no matter who is involved, you don't have to worry. I can transfer you to my department."
Don Scott sneered in his heart, do you think this will work?
This woman is really naive.
Jessica didn't take it seriously at first. She glanced at Jiang Nanzhen and was about to refuse, but she felt attracted by Jiang Nanzhen's eyes.
Those eyes, like the rippling waves of autumn, seemed bottomless, as if they wanted to suck one's soul in.
"I really don't know, but Ilya informed me that it could be approved after receiving a call from the COO."
Jessica regretted it as soon as she said it.
What's going on? Why did I involve the COO?
And when Don Scott heard what Jessica said, he was even more shocked.
Jessica admitted it?
How did this woman from the Great Zhou Dynasty do it?
"You've done a great job. You don't have to worry about anything. You've sacrificed your own interests for the greater good and upheld BlackRock's values. We are all proud of you."
Jiang Nanzhen stared at Jessica closely and comforted her in a gentle tone.
Jessica's eyes were dazed.
Is that so?
When Don Scott saw Jiang Nanzhen's gentle but cold-blooded eyes, his heart felt even colder.
"The company will uphold the principle of confidentiality in today's conversation and won't disclose it to any third party. You can rest assured. Okay, you can leave now."
Jiang Nanzhen waved her hand, and Jessica walked out of the reception room like a zombie.
"Next, Elijah Morello." Jiang Nanzhen flipped through the list and said softly.
Don Scott also looked at the list: "Jane, according to the pre-arranged order, it should be Levi Quick."
Jiang Nanzhen shook her head. "Jessica has just revealed Elia Morello. I hope to strike while the iron is hot and follow this clue as soon as possible to figure out the whole story."
Don Scott's mind moved: "I think we should stick to the established order. If the other investigators find out that we have changed the order of questioning, it may lead to unnecessary associations and cause uncontrollable consequences."
"Uncontrollable consequences?" Jiang Nanzhen pursed her lips and smiled. "If we don't immediately question Elia Morello and give him time to collude with others and destroy evidence, that would be an uncontrollable consequence, right?"
Just as Don Scott was about to speak, he heard Jiang Nanzhen continue, "Or is this what you want to see more, Don?"
Don Scott turned his head suddenly and was about to express his anger when he saw Jiang Nanzhen's fox eyes staring at his face.
Somehow, Don Scott suddenly felt a little timid.
At the same time, a chill came over me.
What does this woman want to do?
"I'm just worried about alerting the enemy." Don Scott shook his head.
"Well, if you're not feeling well, you can go home early." Jiang Nanzhen said calmly, then looked up at the white woman in her thirties and said, "Linda, go get Elijah."
Bai Nu looked at Jiang Nanzhen, then at Don Scott, and after a slight hesitation, she pushed open the door of the conference room and walked out.
…
"As long as the risks are manageable and we support the business units, I don't think this is a problem."
…
"No one told me what to do, yes, this is my answer..."
…
"Yes, the COO called me and asked me to get it approved as soon as possible. He said Qianxun really needs the money and now is a good time. Maybe we can double our profits in three months..."
"Okay, I understand. You can leave now. Next, Reese Layton..."
Hearing Elijah Morello's answer, Don Scott was almost shocked.
What happened? Why did he confess in the middle of a conversation?
Don Scott wiped the cold sweat from his forehead.
It’s over, I can’t hold it back anymore.
A presidential candidate who has been sentenced will naturally not have to serve his sentence if he becomes president. Similarly, not sentencing doctors is a common problem among multinational corporations.
Not to mention the COO, even an ordinary executive committee member should not be involved in such matters!
Besides, who doesn’t know that Robert Goldstein is behind this?
Is it necessary for you to unravel the mystery?
Could it be...
Don Scott seemed to have thought of something, his hair stood on end and he began to fidget.
Have you been involved in a conspiracy?
…
"...Yes, the COO called personally and urged us to complete the approval process as soon as possible."
"Yes, we can only process it as soon as possible, and the Aladdin system's rating for this transaction is..."
"Okay, you can go out now. Call the next one, Qian Xingyi."
…
"...The COO didn't call me, it was his assistant... Yes, I can guarantee with my reputation that I didn't lie..."
"I don't know the full circumstances of the case, but it is indeed unusual, very unusual."
"I'm not sure if there was any fraud involved, but looking at the entire decision-making process, it at least proves one thing: our hasty execution of the investment decision without conducting due diligence was the direct cause of this loss."
"Okay, I'll leave first. I hope you can keep this conversation confidential."
…
"...Robert is a good guy... Well, maybe not exactly, but he's definitely a decisive guy. On some urgent projects, he often helps his team keep pushing the entire process forward. Yes, yes, that's right. Everyone knows he's leading these businesses..."
"That's not the case. It's pretty straightforward to clarify that there's no controlling stake in Qianxun Information Technology and Qianxun Network Technology. I don't think there's anything confusing about this. If our sales staff can't even figure out both, that would be a more serious problem, right?"
…
"...Are you sure this conversation is confidential? Oh, okay, I get it. Listen, Robert Goldstein is trash! After Qianxun's explosion last time, he wanted to push my team out to take the blame and gave me the lowest score in the semi-annual assessment."
"Damn it! Everyone knows Jason Hawthorne is the one actually operating this operation, and Goldstein is the real boss. Yet, he's actually letting a team like us, who have nothing to do with it, shoulder the responsibility. It's simply ridiculous. For the first half of the year, all of us have had our performance deductions deducted due to his shamelessness..."
"Could he do such a thing? Of course, of course he could do it. That's his style."
"Remember the bullying incident last year? Bullshit, don't even mention that to me. It's not a joke. Damn it! If this guy ends up in charge of BlackRock, BlackRock will be doomed in no time."
…………
Don Scott and the other three were almost going crazy. They kept shrinking back and didn't dare to look up.
What on earth is this woman trying to do?
But they can't stop it. If they do, they will be accused of violating regulations, and even their boss Bennett Golub won't be able to save them.
Jiang Nanzhen, however, was not in a hurry and talked to everyone in the entire approval process. By the time he finished talking to the last one, Don Scott was completely numb.
The testimonies of the dozen or so approval flows also firmly nail Robert Goldstein to the point of being a "stupid victim of fraud" or "suspected of using dishonorable means to help Robert Lee embezzle BlackRock's interests."
The former is fine, but if it is the latter, BlackRock can even send him to jail!
No, damn, the former isn't good either. With such a reputation for being "stupid," Goldstein might have a hard time keeping his current position and seat on the Executive Committee, let alone succeeding Robert Capito or Larry Fink.
"Okay, we've discussed everything before. Next up... 'Robert Goldstein,' Linda, please get the COO over here."
Jiang Nanzhen still had her habitual smile on her face, but Don Scott clearly saw a hint of ruthlessness in this woman's eyes.
(End of this chapter)
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