Rule 206(4)‑7 under the Investment Advisers Act of 1940, known as the Compliance Rule, establishes the fundamental parameters for an investment adviser’s regulatory compliance program, including the adoption of appropriate policies and procedures, conducting an annual compliance review and appointing a qualified CCO. A recent installment of ACA Group’s “Building a Gold Standard Compliance Program” series focused on identifying and mitigating conflicts of interest; minimum compliance program requirements; compliance manuals; compliance policies and procedures; desk procedures; and recent SEC compliance-related examination and enforcement activity. The program featured Jaqueline Hummel, director of Thought Leadership, and Myles Blechner, director of investment advisory consulting at ACA Group. This article covers their insights into the fundamental framework for compliance programs, focusing on the identification, evaluation and mitigation of conflicts of interest. It underscores the importance of a collaborative, firm‑wide approach to compliance, strategic interpretation of the Compliance Rule, and regularly updating procedures to navigate the evolving regulatory landscape effectively. See our three-part series on tailoring a compliance program: “Why Fund Managers Should Customize” (Aug. 24, 2021); “What Fund Managers Should Consider” (Aug. 31, 2021); and “When Fund Managers Should Review and Update” (Sep. 14, 2021).