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Regulators Impose Extraordinary Fine Amounts in Recent Off-Channel Communications Enforcement Actions

The Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory Authority (“FINRA”) have, in two separate recent settled enforcement actions involving off-channel communications (“OCC”), imposed fine...more

The Corporate Transparency Act (CTA) is Coming: Creation of a U.S. National Beneficial Ownership Database

Potentially as soon as late 2022 or early 2023, a new U.S. regulatory requirement will come into effect which will affect over 25 million existing business entities and another 3-4 million new entities each year. The...more

Supervision of Vendors When Outsourcing - The Buck Stops with FINRA Member Firms

Key Takeaways: ..On August 13, 2021, FINRA issued Regulatory Notice 21-29 (“RN 21-29”) to remind member firms that they must establish and maintain an adequate supervisory system, including written supervisory procedures...more

Heads Up! Your Form CRS Grace Period Has Ended: The SEC Drops the Hammer on 27 Firms for Compliance Failures with Form CRS Filing...

In case you were wondering if you can still push off finalizing your Form CRS filing, posting it on your website and delivering it to clients, the SEC has read your mind and answered loudly: no more! On Monday, the SEC...more

A Cautionary Tale of a Small Broker-Dealer’s and its Associated Persons’ Failure to Honor FINRA’s Suspension Rules

Being a small business owner is tough. You often wear several hats and juggle multiple responsibilities while you try to build a successful business. This is especially true for small financial services firms that are subject...more

FINRA Reg Notice 17-40: Is Your AML Program Ready For FinCEN’s CDD Rule?

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

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