Chapter 434 Internal Control and Compliance (4416)

Park Avenue Plaza, Manhattan, New York.

Two security guards holding submachine guns stood at the door of a conference room, while inside the room, a dozen financial elites who usually looked shrewd 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, stuck her head in and shouted.

At the conference table, a professional woman with short brown hair stood up with a somewhat nervous look on her face, walked out of the conference room, and, under the guidance of the white woman just now, 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 investigator Don Scott?
Don Scott is not a direct employee of BlackRock. He previously worked at Fosbury 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 at Fosbury, he led the investigations of many of BlackRock's more difficult internal control and compliance cases.

How could it be Don Scott? What on earth is 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? Was she the one 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 hands.

"Jessica Baraham, I'm the 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 30 billion Malaysian dollars?"

Jessica’s heart sank, and she hugged her arms tightly: “I can’t remember it clearly, I may have 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 7:15 am on July 10, you passed the department’s internal approval for this case.”

"In your pre-approval, someone has already 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 has made a clear clarification of the risk and obtained approval. However, we did not include this in your department's approval opinion. Further tracking on this point ended your approval process. You need to give a reasonable explanation."

Jessica was relieved when she heard Don Scott's questioning: "My responsibility is to help the transaction team to finally integrate the approval opinions. In fact, you should be able to see in the system operation records that I once sent this approval back and asked the transaction team to clarify it again, but because this case was very urgent, I asked the upper management for instructions before I finished 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, "Levi Quick, you go call him."

Jessica Baraham's heart skipped a beat, and even though her butt had 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 morality.

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 aware of the incident but do not proactively report it, if it is discovered, you will be charged with the crime of "knowing but not reporting".

Moreover, this kind of “knowingly not reporting” is not the evidence of your “knowingly not reporting”, but rather “reasonable speculation”.

To put it bluntly, I think you definitely know it, and 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 at 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 matter who it is, it is impossible for anyone to 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 a powerful person, after a few months when that person is fine, she will be the first one to be settled.

Sure enough, Jessica’s face 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 insisted that she knew nothing.

Don Enscott coughed and was about to speak when he heard Jiang Nanzhen speak 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 Enscott 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 rippling autumn waves, seemed bottomless, as if they wanted to suck in one's soul.

"I really don't know, but Ilya informed me that I could approve it 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 confessed?
How did this woman from the Great Zhou Dynasty do it?
"You have done a great job. You don't have to have any psychological barriers. You have sacrificed your own interests for the greater good and defended 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 for today's conversation and will not 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 confessed Elijah Morello. I hope to strike while the iron is hot and follow this clue as soon as possible to figure out the whole thing."

Don Scott's mind moved: "I think we should follow the established order. If other people under investigation find out that we have changed the order of questioning, it may lead to unnecessary associations and cause uncontrollable consequences."

"Uncontrollable consequences?" Jiang Nanzhen smiled. "If we don't question Elijah Morello right now 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 sharply, just as he was about to express his anger, 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 on earth 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 call Elijah."

Bai Nu looked at Jiang Nanzhen, then at Don Enscott, 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 in order to support the business unit, 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 go through the approval process as soon as possible. He said Qianxun really needed the money and now is a good time. Maybe I can double my earnings in three months..."

"Okay, got it, you can get out. Next, Reese Layton..."

Don Scott was almost shocked to hear Elijah Morello's answer.

What happened? Why did he confess while talking?
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 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 things!

Besides, who doesn’t know that Robert Goldstein is behind this?

Is it necessary for you to unravel the mystery?

Is it...

Don Enscott 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 us personally and urged us to complete the approval process as soon as possible."

"Yes, we can only handle 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, but his assistant did…Yes, I can use my reputation to guarantee that I didn't lie…"

"I don't know the whole case, but it is indeed unusual, very unusual."

“I don’t know if there was any fraud involved, but looking at the entire decision-making process, it at least proves one thing: we rushed into the investment decision without due diligence, which was the direct cause of this loss.”

"Okay, I'll leave first. I hope you can keep this conversation confidential."

……

"…Robert is a good man…Okay, maybe not, but he is a man of action. On some urgent projects, he often helps his team to keep the whole process moving forward. Yes, yes, that's right. Everyone knows that he is leading these businesses…"

"That's not the case. It's very easy to make it clear that there is no controlling stake between Qianxun Information Technology and Qianxun Network Technology. I don't think there's anything confusing about this. If our business personnel can't even figure out the two, that would be a more fatal problem, right?"

……

"...Are you sure this conversation is confidential? Oh, okay, I get it. Listen to me, 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, everyone knows that Jason Hawthorne is the actual operator, and Goldstein is the real boss, but he actually let a team like us who have nothing to do with him take responsibility. It's ridiculous. In the first half of the year, all of us had our performance deducted because of his shamelessness..."

"Would he be able to 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 mention any jokes to me. That can't be a joke. Damn it, if this guy takes charge of BlackRock in the future, BlackRock will be doomed soon."

…………

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 person, Don Scott was completely numb.

The testimonies of the dozen or so approval flows also firmly nailed Robert Goldstein to the possibility of being a "stupid victim of fraud" or "suspected of using dishonorable means to help Robert Lee encroach on BlackRock's interests."

The former is fine, but if it is the latter, Blackrock can even send him to jail!

No, damn, the former is not good either. With such a "stupid" reputation, Goldstein may 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 the previous ones. Next one is... 'Robert Goldstein'. Linda, please help 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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