Daniel A. Nathan

Daniel A. Nathan

Morrison & Foerster LLP

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SEC Staff Finds that Broker-Dealers Still Are Not Conducting Adequate Section 5 Reviews

The staff of the SEC recently addressed broker-dealers’ obligations when engaging in transactions in unregistered securities by issuing FAQs and a Risk Alert that reported the results of examinations of a number of...more

10/22/2014 - Anti-Money Laundering Broker-Dealer Compliance SEC Securities Act of 1933 Unregistered Securities

Takeaways From Broker-Dealers’ Section 5 Inadequacies

The staff of the U.S. Securities and Exchange Commission recently addressed broker-dealers’ obligations when they engage in transactions in unregistered securities by issuing FAQs and a risk alert that reported the results of...more

10/22/2014 - Anti-Money Laundering Broker-Dealer Compliance Fraud Market Manipulation SEC Unregistered Securities

FINRA Focuses AML Enforcement on a BD Doing Business in Mexico

The Financial Industry Regulatory Authority (FINRA) recently took formal disciplinary action against a New York-based broker-dealer that is affiliated with a Mexican broker-dealer and a Mexican bank for inadequate anti-money...more

2/7/2014 - Anti-Money Laundering Broker-Dealer FINRA Foreign Banks Mexico

A Must Read: FINRA’s 2014 Exam Priorities

FINRA did not wait for any dust (or snow) to settle on the New Year before alerting the brokerage industry and the public about its regulatory and examination priorities for 2014. This year’s letter, issued earlier than ever...more

1/6/2014 - Algorithmic Trading Anti-Money Laundering Broker-Dealer Compliance Conflicts of Interest Crowdfunding Employer Liability Issues Enforcement FINRA High Frequency Trading Qualified Benefit Plans Recidivism

FINRA Continues its Crackdown on Companies that Fail to Respond to Red Flags

FINRA continues to discipline broker-dealers that fail to detect and investigate so-called “red flags” of suspicious account activity. Yesterday, FINRA announced a $1 million fine against COR Clearing LLC (the “Firm”) –...more

12/19/2013 - Anti-Money Laundering Compliance Enforcement Actions FINRA

FINRA Increases the Cost of Penny Stock-Related AML Deficiencies

The price tag for failing to detect suspicious activity in penny stocks through an adequate anti-money laundering program continues to increase. Oppenheimer & Co., Inc. recently agreed to pay FINRA more than $1.4 million to...more

8/16/2013 - Anti-Money Laundering FINRA Internal Controls Money Laundering Stocks

FINRA Focuses on Anti-Money Laundering Procedures and Red Flags

Last week, the Financial Industry Regulatory Authority (FINRA) publicized penalties against three companies – as well as four associated individuals – that it found had failed to establish and implement adequate procedures...more

5/17/2013 - Anti-Money Laundering Bank Secrecy Act FINRA Red Flags Rule

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