News & Analysis as of

Anti-Money Laundering Broker-Dealer Policies and Procedures

Orrick, Herrington & Sutcliffe LLP

FINRA fines broker-dealer $500K for failure to file suspicious activity reports

On August 22, FINRA accepted a Letter of Acceptance, Waiver, and Consent (AWC) from a broker-dealer member firm regarding its alleged failure to establish and implement policies and procedures designed to detect suspicious...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Parker Poe Adams & Bernstein LLP

Practical Tips for Broker-Dealers After SEC Flags Compliance Issue

Last month, the U.S. Securities and Exchange Commission (SEC) took a refreshed look at how broker-dealers are complying with anti-money laundering rules. What auditors discerned — as detailed in their July 31 risk alert — is...more

K2 Integrity

SEC Division of Examination Risk Alert Highlights Deficiencies in Broker-Dealers’ AML Compliance Programs

K2 Integrity on

The U.S. Securities and Exchange Commission (SEC) is responsible for protecting investors and ensuring the integrity of the securities markets. As part of this mission, the SEC requires broker-dealers to comply with...more

Morrison & Foerster LLP

Risk Alert: Broker-Dealers Must Comply with Their AML and Sanctions Obligations

On July 31, 2023, the Securities and Exchange Commission’s (SEC) Division of Examinations (EXAMS) issued a risk alert summarizing observations from its recent anti-money laundering (AML) and counter-financing of terrorism...more

Oberheiden P.C.

5 Anti-Money Laundering Compliance and Defense Tips

Oberheiden P.C. on

1. AML Laws - Federal anti-money laundering (“AML”) laws are complex in nature and apply to a broad category of institutions and businesses. One of the most important AML laws is the Bank Secrecy Act, which obligates...more

Faegre Drinker Biddle & Reath LLP

Risky Business: SEC Risk Alert Highlights Broker-Dealers’ Anti-Money Laundering Miscues and Encourages Firms to Beef Up Protection

Ben Franklin once said “by failing to prepare, you prepare to fail.” Based on the SEC’s latest risk alert concerning broker-dealers’ anti-money laundering (AML) compliance (or lack thereof), some firms would be well served to...more

Bracewell LLP

SEC's Office of Compliance Inspections and Examinations 2018 Examination Priorities

Bracewell LLP on

On February 7, 2018, the Office of Compliance Inspections and Examinations (“OCIE”) of the U.S. Securities and Exchange Commission (“SEC”) published its 2018 examination priorities. OCIE’s examination priorities are...more

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