News & Analysis as of

Securities and Exchange Commission (SEC) Recordkeeping Requirements New Guidance

Eversheds Sutherland (US) LLP

SEC publishes broker-dealer and transfer agent crypto custody guidance

On May 15, the SEC staff provided guidance to SEC-registered broker-dealers and transfer agents on how they can custody and recordkeep digital assets. According to the guidance, non-securities are not subject to the...more

Cadwalader, Wickersham & Taft LLP

SEC Exempts Brokers and Dealers from Rule 15c2-11 Review and Recordkeeping Requirements for Quotations on 144A Fixed Income...

On October 30, 2023, the Securities and Exchange Commission issued an order (the “Order”) that grants exemptive relief under Rule 15c2-11 under the Securities Exchange Act of 1934 to brokers and dealers that publish...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - August 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Holland & Knight LLP

Do Not Delete: SEC and DOJ Send Serious Messages on Preserving Ephemeral Communications

Holland & Knight LLP on

Ages ago, hieroglyphics were painstakingly etched into stone. They communicated various types of messages, from fables to business transactions, and lasted thousands of years. Today, we still communicate the same type of...more

Akin Gump Strauss Hauer & Feld LLP

SEC OCIE Issues Guidance on Advisers’ Recordkeeping Requirements for Electronic Messaging Following its Sweep Examination

• On December 14, the SEC’s OCIE issued a Risk Alert summarizing the findings of its limited-scope examination initiative relating to electronic messaging. • Noting a “pervasive use” of electronic messaging by adviser...more

Foley & Lardner LLP

DOJ Issues New FCPA Policy Offering Incentives to Encourage Disclosure of Foreign Bribery and Corruption Misconduct

Foley & Lardner LLP on

On November 29, 2017, Deputy Attorney General Rod Rosenstein announced that the U.S. Department of Justice (DOJ) was issuing a new enforcement policy covering its enforcement of the Foreign Corrupt Practices Act (FCPA). The...more

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