In what most will find a shocking and unjust ruling, on February 16, 2021, Judge Furman of the United States District Court for the Southern District of New York ruled in In re Citibank August 11, 2020 Wire Transfers that...more
On July 9, 2019, the United Kingdom’s Financial Conduct Authority (FCA) published its latest Enforcement annual performance report for the year 2018/19. This follows the publication of its final FCA Mission: Approach to...more
7/26/2019
/ Compliance ,
Corporate Investigations ,
Enforcement ,
Enforcement Statistics ,
Financial Conduct Authority (FCA) ,
Financial Industry Regulatory Authority (FINRA) ,
Hong Kong ,
Hong Kong Securities and Futures Commission (HKSFC) ,
Information Reports ,
OCIE ,
Securities and Exchange Commission (SEC) ,
UK
In October 2005, we wrote an article titled “Cooperation, Only More So: What It Takes to Receive Credit for Cooperating with NASD.” The title came from a line in the movie Casablanca. In it, Rick (Humphrey Bogart) is asked...more
During the past several years, the US Securities and Exchange Commission (SEC) has settled more than a dozen cases where the SEC alleged (with the firms neither admitting nor denying the charges) that investment advisers...more
1/28/2019
/ 12b-1 plan ,
Administrative Law Judge (ALJ) ,
Broker-Dealer ,
Conflicts of Interest ,
Disclosure Requirements ,
Enforcement Actions ,
Failure To Disclose ,
Form ADV ,
Investment Adviser ,
Investment Company Act of 1940 ,
Securities and Exchange Commission (SEC) ,
Transaction Fees
On December 3, 2018, the US Department of the Treasury’s Office of Terrorism and Financial Intelligence, the federal depository institutions regulators and the Financial Crimes Enforcement Network (FinCEN) (together, the...more
The Share Class Initiative -
On February 12, 2018, the Division of Enforcement of the US Securities and Exchange Commission (SEC) announced the Share Class Selection Disclosure Initiative (Initiative), which informed SEC...more
On February 12, 2018, the Division of Enforcement of the US Securities and Exchange Commission (SEC) announced the Share Class Selection Disclosure Initiative (Initiative) to encourage SEC registered investment advisers...more
This legal alert is the first in a series addressing the ever-changing regulatory landscape relating to senior investors, state law, and a broker-dealer’s legal obligation, if any, to protect its vulnerable customers. We...more
On April 10, 2017, the Financial Industry Regulatory Authority’s (FINRA) National Adjudicatory Council (NAC) introduced new Sanction Guidelines (Guidelines) which allow the NAC and FINRA staff to take into consideration the...more
As the football season was winding down, on January 4, 2017, the Financial Industry Regulatory Authority (FINRA) published its 2017 Annual Regulatory and Examination Priorities Letter. According to FINRA President and CEO,...more
Introduction -
In addition to the recent increase in regulatory focus on senior investors, earlier this fall, the Financial Industry Regulatory Authority (FINRA) filed a rulemaking proposal (the filing) with the...more
Highlights from FINRA/SIFMA Senior Investor Conference -
On October 22-23, members of the securities industry, academia, regulators, and public policy experts gathered in Washington, D.C., at the joint Financial...more