More than two years after announcing the first round of settlements in the ongoing “off-channel communications” probe, the SEC recently announced another round of settlements with 26 financial firms, totaling $390 million in...more
Over the last several years, the Securities and Exchange Commission (“SEC”) has been laser-focused on the use of so-called “off-channel communications” in the financial services industry. On the theory that employees’ use of...more
4/22/2024
/ Books & Records ,
Broker-Dealer ,
Electronic Communications ,
Employees ,
Enforcement Actions ,
Financial Services Industry ,
Investigations ,
Investment Adviser ,
Mobile Apps ,
Mobile Devices ,
Private Equity ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Violations
Just one day after Deputy Attorney General Lisa Monaco announced the U.S. Department of Justice’s (“DOJ’s” or “Department’s”) whistleblower pilot program on March 8, 2024, the DOJ’s Criminal Division highlighted its plans to...more
The United States Department of the Treasury has announced that it is working to address what it perceives as money laundering risks associated with investment advisers. Specifically, the agency asserts that absent consistent...more
1/11/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Broker-Dealer ,
BSA/AML ,
Financial Crimes ,
Financial Institutions ,
Investment Adviser ,
Money Laundering ,
Proposed Regulation ,
Proposed Rules ,
Recordkeeping Requirements ,
Reporting Requirements ,
Rulemaking Process ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
On September 29, 2023, Albemarle Corporation (“Albemarle”), a global chemical manufacturer, reached an agreement with the U.S. Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) to resolve...more
Over the last several years, the Securities and Exchange Commission (the “SEC”) and the Commodities Futures Trading Commission (“CFTC”) have been laser-focused on the use of so called “off-channel communications” in the...more
5/26/2023
/ Books & Records ,
Broker-Dealer ,
CFTC ,
Electronic Communications ,
Employees ,
Financial Institutions ,
Instant Messaging Apps ,
Investigations ,
Investment Adviser ,
Mobile Apps ,
Mobile Devices ,
Policies and Procedures ,
Securities and Exchange Commission (SEC) ,
Social Media ,
Swap Dealers
Over the last year, the U.S. Securities and Exchange Commission (“SEC”) has been laser-focused on the use of personal devices by employees of the large Wall Street banks to conduct company business. The SEC’s investigations...more
In May, we saw a slower month for crypto enforcement actions by state and federal regulators. See our March 2022 Crypto Enforcement Actions Roundup blog here where we discuss the regulatory guidance and jurisdiction of...more
6/7/2022
/ Blockchain ,
California ,
CFTC ,
Corporate Counsel ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
FinCEN ,
Governor Newsom ,
Popular ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury