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
4/24/2024
/ Broker-Dealer ,
Compliance ,
Electronic Communications ,
Electronically Stored Information ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Policies and Procedures ,
Recordkeeping Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act
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
“Statutory disqualification” as defined under Section 3(a)(39) of the Securities Exchange Act of 1934 (“the Exchange Act”), prevents a person under a statutory disqualification from associating with any FINRA Member Firm...more
A recent Securities and Exchange Commission (“SEC”) order imposed sanctions on a financial institution for failing to reasonably supervise a representative’s conduct. In its findings, the SEC highlights the institution’s...more
4/15/2019
/ Best Practices ,
Broker-Dealer ,
Financial Institutions ,
Investigations ,
Investment Adviser ,
Policies and Procedures ,
Professional Misconduct ,
Registered Representatives ,
Rule 10b-5 ,
Securities Act ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations
So you want to use the government’s EB-5 Immigrant Investor Program (“EB-5 Program”) to raise cash? Be aware that the SEC will be looking over your shoulder to determine whether you are acting as an unregistered broker-dealer...more