With limited amendments to its proposed rule, the Financial Crimes Enforcement Network (“FinCEN”), a division of the U.S. Department of the Treasury, recently promulgated its final rule (the “Reporting Rule”) implementing the...more
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
10/21/2021
/ Anti-Money Laundering ,
Consent Order ,
Enforcement Actions ,
Enforcement Priorities ,
Financial Industry Regulatory Authority (FINRA) ,
FinCEN ,
Investment Adviser ,
Know Your Customers ,
Petition for Writ of Certiorari ,
Risk-Based Approaches ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Suspicious Activity Reports (SARs) ,
Unregistered Brokers
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
6/7/2021
/ Anti-Money Laundering ,
Chief Compliance Officers ,
Compliance ,
Corporate Fines ,
Due Diligence ,
Enforcement ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Foreign Financial Institutions (FFI) ,
Internal Controls ,
Regulatory Violations ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
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
6/1/2018
/ Anti-Money Laundering ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Customer Identification Program (CIP) ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
OCIE ,
Personal Liability ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
On November 21, 2017, FINRA issued Regulatory Notice 17-40 to provide member firms guidance regarding their obligations under FINRA Rule 3310 (Anti-Money Laundering Compliance Program) in light of the Financial Crimes...more
The SEC recently charged a New York-based broker-dealer, Windsor Street Capital, L.P. (f/k/a Meyers Associates, L.P.) and John David Telfer, who acted as Windsor’s Chief Compliance and Anti-Money Laundering Officer for...more