News & Analysis as of

Securities and Exchange Commission (SEC) Enforcement Actions Suspicious Activity Reports (SARs)

Orrick, Herrington & Sutcliffe LLP

Broker-dealer to pay $1.19M for suspicious activity reporting violations

On August 12, the SEC issued published a settled enforcement action order against a broker-dealer for failing to monitor, investigate, and file Suspicious Activity Reports (SARs) between March 2020 and May 2023, violating...more

Ballard Spahr LLP

Binance Settles Criminal and Civil AML and Sanctions Enforcement Actions for Multiple Billions – While its Founder, Owner and...

Ballard Spahr LLP on

As the world now knows, Binance Holdings Limited, doing business as Binance.com (“Binance” or the “Company”), has entered into a plea agreement with the U.S. Department of Justice (“DOJ”)....more

Holland & Knight LLP

Twinkle-Twinkle Little SAR: SEC & FINRA Settle with Broker-Dealers and Registered Rep

Holland & Knight LLP on

In a series of settlements announced this year, the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) penalized several broker-dealers for allegedly failing to file...more

WilmerHale

SEC Enforcement Actions Reflect Expansion of SEC’s AML Compliance Focus: Broker-Dealers, Investment Advisers, Registered...

WilmerHale on

The Securities and Exchange Commission (SEC) recently announced anti-money laundering (AML)-related charges against an individual registered representative for failing to escalate red flags of potentially suspicious activity,...more

Morrison & Foerster LLP

Top 5 SEC Developments for July 2023

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important SEC enforcement developments from the past month, with links to primary resources. This...more

BCLP

Continuing AML regulatory issue focus: A look at a recent SEC enforcement case, the SEC’s response to Petition for Certiorari, and...

BCLP on

Garcia Case Highlights Necessity of Knowing Your Customer and Listening to Internal Fraud Watchdogs. The SEC’s recent Order against a broker-dealer (the “Firm”) imposed a $750,000 financial penalty for the Firm’s failure...more

Proskauer - Corporate Defense and Disputes

June 2021 Update of the SEC’s Covered Actions for Potential Whistleblower Claims

On June 30, 2021, the SEC posted six Notices of Covered Actions, for which individuals have 90 calendar days to apply for a whistleblower award.  As discussed in our prior post, the SEC publishes Notices for cases in which...more

BCLP

Anti-Money Laundering Continues to be Among the Highest Regulatory Priorities, As Evidenced by Recent Enforcement Cases and...

BCLP on

For the past decade, anti-money laundering (“AML”) has been at the forefront of securities regulators’ priorities.  Indeed, AML enforcement cases have resulted in some of the highest fines imposed by securities regulators,...more

Jones Day

SEC’s Division of Examinations Signals Continuing Focus on Broker-Dealer AML Compliance Obligations

Jones Day on

The Situation: The Securities and Exchange Commission’s Division of Examinations ("EXAMS") released a Risk Alert on March 29, 2021, reminding broker-dealers of their obligation to comply with anti-money laundering ("AML")...more

Goodwin

Biden Administration Issues Regulatory Freeze On New Agency Rules

Goodwin on

In this Issue. In one of its first acts after being installed on January 20, the Biden Administration issued a regulatory freeze on new agency rules that have been adopted but are not yet effective; in one of its final acts...more

Snell & Wilmer

New Year, New Laws – Congress Passes Major Anti-Money Laundering Act

Snell & Wilmer on

On January 1, 2021, Congress passed the National Defense Authorization Act for Fiscal Year 2021, an omnibus bill that includes the Anti-Money Laundering Act of 2020 (“AMLA”). The AMLA bans the use of anonymous shell companies...more

Morgan Lewis

Year in Review: Select SEC and FINRA Developments and Enforcement Cases

Morgan Lewis on

The Morgan Lewis Year in Review highlights key US Securities and Exchange Commission (the SEC or the Commission) and Financial Industry Regulatory Authority (FINRA) enforcement and examination developments, and cases...more

K&L Gates LLP

FinTech Forward: Blockchain, ICOs, and Cryptocurrencies

K&L Gates LLP on

In this episode, Jeremy McLaughlin and Dan Cohen discuss blockchain use cases, and the regulatory trends and associated frameworks for ICOs, and cryptocurrencies. In particular, they provide an overview of the application of...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

White & Case LLP on

TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more

Ballard Spahr LLP

Court Decision Reinforces SAR Obligations of Penny Stock Clearing Brokers

Ballard Spahr LLP on

Second Post in a Two-Part Series - Opinion Stresses Importance of Narrative Sections and Supporting Documentation for SARs - In our first post in this series, we discussed the Securities and Exchange Commission’s...more

Ballard Spahr LLP

Clearing Broker Continues to Take Aim at SEC’s Ability to Enforce the BSA

Ballard Spahr LLP on

First Post in a Two-Part Series - On December 11, Judge Denise Cote of the Southern District of New York granted, in part, the Securities and Exchange Commission’s (“SEC”) motion for summary judgement in its action against...more

The Volkov Law Group

UBS Pays $15 Million for AML Compliance Deficiencies

The Volkov Law Group on

UBS Group agreed to pay a combined $15 million penalty to the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”)and the SEC for regulatory deficiencies in its anti-money laundering compliance program. ...more

Orrick, Herrington & Sutcliffe LLP

The SEC's Authority to Enforce the BSA Is Challenged

In the past few years, the SEC has become increasingly active in bringing enforcement actions based on broker-dealers' alleged failures to comply with requirements of the Bank Secrecy Act (BSA), in particular that requirement...more

A&O Shearman

Company Settles With The SEC For Allegedly Failing To File Required Suspicious Activity Reports

A&O Shearman on

On July 2, 2018, the Securities and Exchange Commission (“SEC”) filed a one-count complaint in District Court for the Northern District of California against Charles Schwab Corp. (“Schwab” or the “Company”) for allegedly...more

BCLP

Recent Developments Confirm AML is a Regulatory "Hot Button"

BCLP on

The SEC continues to reiterate the role of broker-dealers as “gatekeepers to the securities markets” by focusing on firms’ anti-money laundering (“AML”) obligation. The import that the SEC, as well as FINRA, places on firms’...more

Ballard Spahr LLP

SEC Sanctions Broker-Dealer, Clearing Firm and Chief Compliance Officer for AML Violations

Ballard Spahr LLP on

On May 16, 2018, the Securities Exchange Commission (“SEC”) announced it had settled charges against a registered broker-dealer, its clearing firm, and its chief compliance and anti-money laundering (“AML”) officer brought...more

A&O Shearman

FINRA And SEC Fine Two Entities For Anti-Money Laundering Compliance Deficiencies And Other Violations

A&O Shearman on

On May 16, 2018, the Financial Industry Regulatory Authority (FINRA) announced a $5.3 million fine on a financial services company (ICBCFS) for alleged systemic anti-money laundering (AML) compliance failures, including an...more

Ballard Spahr LLP

Continued Individual Liability Under the Bank Secrecy Act: The SEC Targets Two AML Compliance Officers and One CEO for Alleged...

Ballard Spahr LLP on

A recent anti-money laundering (“AML”) enforcement action reminds us of the increasing risk of individual liability for alleged violations of the Bank Secrecy Act (“BSA”), a key issue about which we have blogged....more

A&O Shearman

SEC And FINRA Fine Broker-Dealer, CEO, And Compliance Officer For Failing To File Suspicious Activity Reports

A&O Shearman on

On March 28, 2018, the Securities and Exchange Commission (“SEC”) instituted settled administrative proceedings against broker-dealer Aegis Capital Corporation (“Aegis”), its founder and Chief Executive Officer (“CEO”), and...more

Katten Muchin Rosenman LLP

Bridging the Weeks - April 2018

Two broker-dealers’ purported failure to act on red flags – both involving customer trading – resulted in separate Securities and Exchange Commission enforcement actions against the firms. In connection with one action, two...more

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