On June 30, 2022 the Securities and Exchange Commission (SEC) brought a settled enforcement case against a Chief Compliance Officer (CCO) and a Registered Investment Adviser (RIA). At first glance, the case appears...more
9/9/2022
/ Aiding and Abetting ,
Chief Compliance Officers ,
Compliance ,
Corporate Counsel ,
Corporate Officers ,
Enforcement Actions ,
Failure To Disclose ,
Personal Liability ,
Policies and Procedures ,
Registered Investment Advisors ,
Securities Violations
Many compliance officers believe they have targets on their backs. Indeed, according to industry-wide surveys conducted by the National Society of Compliance Professional (NSCP), 72% of compliance professionals are concerned...more
Last week, yet another US Department of Justice (DOJ) official reportedly stated new corporate settlements “most likely” will include a requirement that the company’s chief compliance officer (CCO), as well as the chief...more
During the past few months, the US Treasury, the US banking agencies, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) have pursued several regulatory or enforcement initiatives...more
1/21/2022
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Regulators ,
CFTC ,
Commodity Exchange Act (CEA) ,
Compliance ,
Consumer Protection Laws ,
Enforcement Authority ,
Information Reports ,
OCC ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Stablecoins ,
U.S. Treasury ,
Working Groups
When you think about it, puns are kind of like securities enforcement actions. They could make you groan; they could make you laugh (if the conduct is particularly goofy) (or if you don’t like the respondent); or they often...more
Many of us watched Friends when it was originally broadcast using our rabbit ear antennas or through basic cable. Others watched it on reruns. While, more recently, some of us (or our children) watched on Netflix or, even...more
Often, there are quotes, spellings, symbols, events, or experiences that many of us “know” occurred, but which did not actually happen. This phenomenon is known as the “Mandela Effect,” or “collective false memory.” Its name...more
On July 9, 2019, the United Kingdom’s Financial Conduct Authority (FCA) published its latest Enforcement annual performance report for the year 2018/19. This follows the publication of its final FCA Mission: Approach to...more
7/26/2019
/ Compliance ,
Corporate Investigations ,
Enforcement ,
Enforcement Statistics ,
Financial Conduct Authority (FCA) ,
Financial Industry Regulatory Authority (FINRA) ,
Hong Kong ,
Hong Kong Securities and Futures Commission (HKSFC) ,
Information Reports ,
OCIE ,
Securities and Exchange Commission (SEC) ,
UK
On January 28, 2014, the U.S. Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert entitled: Investment Adviser Due Diligence Processes for Selecting...more
Originally published in Thomson Reuters - Securities Regulation Law Journal - Winter 2012.
Faced with the possibility of litigating against the Securities and Exchange Commission (SEC) or the Financial Industry...more