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Enforcement Actions Recordkeeping Requirements Financial Services Industry

BakerHostetler

DSIR Deeper Dive: Information Governance - Communication Retention Challenges and a Return-to-Office Reaction

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Let’s say, once upon a time, you worked from home during the pandemic. If so, did you use a variety of communication methods (perhaps switching among different platforms, never sure which camera or microphone would be...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Acting Chair Caroline D. Pham Announces CFTC’s 30-Day Enforcement Sprint

On February 25, 2025, the U.S. Commodity Futures Trading Commission (CFTC) released an enforcement advisory regarding the impact of self-reporting, cooperation and remediation in enforcement cases (the “Enforcement...more

Dinsmore & Shohl LLP

SEC Enforcement Actions Related to Electronic Communications Recordkeeping Failures

Dinsmore & Shohl LLP on

On January 13, 2025 the U.S. Securities and Exchange Commission (SEC) announced settled Administrative Proceedings against three broker/dealers and nine investment advisers related to electronic communications recordkeeping...more

Akin Gump Strauss Hauer & Feld LLP

“Under the Wire” E-Comms Settlements: More Confusion Than Closure

On January 13, 2025, the U.S. Securities and Exchange Commission announced settled enforcement actions with five registered investment advisers for failing to maintain and preserve internal electronic communications. These...more

Davis Wright Tremaine LLP

Broker-Dealer Disciplinary Actions: Takeaways From 2024 (So Far)

The U.S. Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA), and the Exchanges were active across a host of regulatory issues impacting fintech companies and broker-dealers during...more

White & Case LLP

The Shadow Financial System

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The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

Mayer Brown

WhatsApp All Over Again: The SEC Brings More Recordkeeping Charges Against Broker-Dealers and Investment Advisers for Off-Channel...

Mayer Brown on

On February 9, 2024, the Securities and Exchange Commission (SEC) announced charges against five broker-dealers, seven dually registered broker-dealers and investment advisers, and four affiliated investment advisers for...more

The Volkov Law Group

Pain in the App: Messaging Apps Lead to Large SEC Enforcement Actions

The Volkov Law Group on

On September 29, 2023, the U.S. Securities and Exchange Commission charged several firms with recordkeeping failures. These recordkeeping failures relate to pervasive and longstanding off-channel communications.  Generally,...more

Walkers

What can we learn from recent enforcement actions in the Cayman Islands?

Walkers on

Walkers' regulatory partners Lucy Frew and Ian Mason consider the learning points for financial services providers (FSPs) from recent enforcement actions by Cayman regulatory bodies. While financial services and related...more

Robinson & Cole LLP

With $1.1 Billion Penalty Deal, SEC Joins DOJ in Firing Warning Shot at Financial Services Industry About Outdated Employee...

Robinson & Cole LLP on

Last week, the United States Securities and Exchange Commission (SEC) fined 16 Wall Street firms a total of $1.1 billion for recordkeeping violations based on the failure to maintain employees’ electronic communications, such...more

Goodwin

SEC Finalizes Reforms Under Investment Advisers Act

Goodwin on

In this Issue. The Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more

BCLP

Financial Professionals Texting Clients? SEC Signals Compliance Failures Can Lead to Significant Penalties

BCLP on

On September 23, 2020, the U.S. Securities and Exchange Commission (“SEC”) entered an Order Instituting Administrative and Cease and Desist Proceedings (“Order”) against a broker-dealer, JonesTrading Institutional Services,...more

Ballard Spahr LLP

CFPB “Can Improve” Recordkeeping and Notifications of Purpose in Civil Investigative Demands, OIG Finds

Ballard Spahr LLP on

On September 20, 2017, the Federal Reserve’s Office of Inspector General (“OIG”) issued a report on the CFPB’s process for issuing Civil Investigative Demands (“CID”). The OIG found that the CFPB “generally complied” with...more

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