News & Analysis as of

Policies and Procedures Scams Enforcement Actions

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

Perkins Coie

SEC 21(a) Report Warns Public Company Email Scam Victims of Bigger Problems Than Stolen Money

Perkins Coie on

Known by many names, including business email compromise fraud, CEO or CFO fraud, impersonation attacks, or “Man-in-the-Email” scams, cyber-related frauds involving spoofed or otherwise compromised business electronic...more

Akin Gump Strauss Hauer & Feld LLP

SEC Warns Companies of Potential Internal Accounting Control Violations with Business Email Compromise

• The SEC issued guidance in the form of a rare “21(a) report” this week after investigating a series of email frauds impacting 9 unnamed companies. • These email-based frauds, referred to as “CEO scams” or “vendor scams,”...more

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