After a period of astounding growth in the special purpose acquisition company (SPAC) market, FINRA recently joined the SEC in announcing further scrutiny of broker-dealers and their affiliates involved in SPAC offerings,...more
The U.S. Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA) have each published their annual examination priorities for 2021, signaling areas of scrutiny that broker-dealers should...more
4/9/2021
/ Anti-Money Laundering ,
Broker-Dealer ,
Compliance ,
Conflicts of Interest ,
Cybersecurity ,
Data Protection ,
Financial Industry Regulatory Authority (FINRA) ,
Phishing Scams ,
Ransomware ,
Risk Mitigation ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
Recent Enforcement Actions and Guidance from DOJ, FinCEN, and OFAC Demonstrate the Increased Commitment — and Cooperation — of Federal Regulators to Police Digital Currencies, Including Their Use in Ransomware Attacks -
Amid...more
11/16/2020
/ Bitcoin ,
Cryptocurrency ,
Cyber Attacks ,
Department of Justice (DOJ) ,
Digital Assets ,
Digital Currency ,
Enforcement Actions ,
Enforcement Guidance ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Securities and Exchange Commission (SEC)
Thwarting the financial exploitation of seniors and other vulnerable investors has been an increasing focus of several financial regulators in recent years, including the Financial Industry Regulatory Authority (“FINRA”). In...more
On January 7, 2020, the Securities and Exchange Commission (“SEC”) issued its 2020 Examination Priorities, a yearly publication highlighting new and existing areas of focus for the Office of Compliance Inspections and...more
1/16/2020
/ Anti-Money Laundering ,
Broker-Dealer ,
Cybersecurity ,
Financial Industry Regulatory Authority (FINRA) ,
FinTech ,
Form CRS ,
Investment Adviser ,
OCIE ,
Regulation Best Interest ,
Retail Investors ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Standard of Care
It’s been nearly five months since the Securities and Exchange Commission (“SEC”) approved Regulation Best Interest: The Broker-Dealer Standard of Conduct (“Reg BI”). As discussed in our June 27, 2019 Client Alert, Reg BI...more
11/1/2019
/ Broker-Dealer ,
Fiduciary Duty ,
Financial Industry Regulatory Authority (FINRA) ,
Form CRS ,
Investment Adviser ,
Investment Management ,
Investors ,
Legislative Agendas ,
Regulation Best Interest ,
Retail Investors ,
Securities and Exchange Commission (SEC) ,
Securities Transactions ,
Standard of Conduct
The SEC signaled last week that it appears to be growing more comfortable approving certain digital asset activities, qualifying the first two initial coin offerings ever to proceed as registered securities....more
FINRA yesterday issued long-anticipated guidance concerning credit for extraordinary cooperation in the context of enforcement investigations. Like its government counterparts, FINRA hopes to incentivize member firms that go...more
On June 5, 2019, the Securities and Exchange Commission (“SEC”) voted to adopt Regulation Best Interest: The Broker-Dealer Standard of Conduct (hereinafter, “Regulation BI”), requiring broker-dealers and their associated...more
Recently, the Financial Industry Regulatory Authority (“FINRA”) and the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) separately issued important guidance regarding customer communications surrounding the...more
5/3/2019
/ Broker-Dealer ,
Confidential Communications ,
Consumer Privacy Rights ,
Disclosure Requirements ,
Financial Industry Regulatory Authority (FINRA) ,
New Guidance ,
OCIE ,
Personally Identifiable Information ,
Privacy Policy ,
Registered Investment Advisors ,
Regulation S-P ,
Securities and Exchange Commission (SEC) ,
Security and Privacy Controls
Stepping outside of SWIFT -
Since its inception more than a decade ago, cryptocurrency has been viewed as a way to supplant traditional global methods of exchanging money. Today, as virtual currencies proliferate,...more
2/19/2019
/ Corruption ,
Cryptocurrency ,
Digital Currency ,
Economic Sanctions ,
Initial Coin Offering (ICOs) ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Self-Regulatory Organizations ,
SWIFT ,
Virtual Currency
On January 28, 2019, FINRA announced a novel leniency initiative that will offer no-fine enforcement resolutions for member firms that self-report supervisory deficiencies related to recommendations of 529 savings plans and...more