Key Discovery Points: Be a Team Player When It Comes to Production
Episode 378 -- Update on Export Controls and Sanctions Enforcement
Key Discovery Points: If You Dispose of Relevant Hard Drives You Will Face (Some) Consequences
eDiscovery Case Law Podcast: How Failing to Meet and Confer Effectively Can Lead to Sanctions
Episode 339: Four Sanctions Cases Everyone Should Know
Corruption, Crime and Compliance - “The New FCPA”: Sanctions and Export Control Enforcement and Compliance
Giving Compliance Advice
Corruption, Crime, & Compliance - Five Steps to Enhance Your Sanctions Compliance Program
Corruption, Crime and Compliance - Deep Dive Into Wells Fargo’s $30 Million OFAC Settlement
FINCast Ep. 36 – Regulators’ Roundtable to Forecast 2023
Guidepost in Motion EP25: State of Compliance with Alixandra Smith Part 2
FCPA Compliance Report - Matt Silverman on Potential Sanctions Against Russia
Argentina: A Look at the Case of Lázaro Báez - Laundering the Proceeds of Corruption and Tax Fraud
Nota Bene Podcast Episode 131: U.S. Sanctions Against Russia: Valid or Ineffective Economic Policy? with Fatema Merchant and Mario Torrico
Compliance into the Weeds - SAP Trade Sanctions Enforcement Action
What to Expect from the Biden Administration
A Look Ahead at the Biden Administration’s Regulatory and Enforcement Priorities
Compliance Perspectives: The German Corporate Sanctions Act
Episode 153 -- The Mighty Amazon Falls to OFAC Enforcement Sword
Navigating an Increasingly Complex Sanctions Landscape: New Exposures for Corporations and Shipping
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced on July 15, 2025, that Interactive Brokers LLC (“IB”)—a globally active electronic brokerage firm headquartered in Greenwich,...more
Federal regulators have cracked down on the use of texts messages and messaging platforms for business communications, using their broad authority to root out record retention violations, resulting in significant fines and...more
Background - On August 30, 2021, the Securities and Exchange Commission (SEC) sanctioned eight firms in three actions for cybersecurity failures in their policies and procedures that exposed the personal information of...more
There is little doubt that the U.S. Securities and Exchange Commission is making cybersecurity a top priority. SEC Chair Gary Gensler told a Senate committee on Tuesday, September 14, 2021 that the agency is developing a...more
Ninth Circuit Holds Loss Causation May Be Predicated on Information Potentially Available Under Freedom of Information Act; D.C. Circuit Upholds FINRA’s Permanent Ban of Broker Accused of Misconduct After Finding SCOTUS...more
I dare you. In fact, I double-dog dare you to figure out how or why FINRA decides to charge willfulness in some cases but not in others. Bottom line is that it is nearly impossible (except if you’re a big firm, in which case...more
Seems like just days ago I blogged about Jessica Hopper and her commitment to providing restitution to customers. Since I posted that blog, there were two other settlements (which I added to that blog as updates) in which...more
I may have said this before in another post, but in my opinion, whether a baseball umpire is good or bad is not a matter of whether he has a low strikezone, a high strikezone, or a wide one. What matters is that whatever that...more
A proprietary trading firm was sanctioned by a sixth futures-industry regulator for purported spoofing trades by one of three employees many years ago. For the employees’ aggregate alleged misconduct, the firm was first...more
The day after Christmas, FINRA issued a press release announcing that five big firms – Citigroup, J.P. Morgan Chase, LPL, Morgan Stanley and Merrill Lynch – had each entered into a settlement, collectively agreeing to pay a...more
On August 20, 2019, the Securities and Exchange Commission (“SEC”) charged Mosaic Capital, LLC, formerly known as AOC Securities, LLC (“AOC”), and its CEO with failing to adequately supervise an employee who engaged in...more
FINRA loves to tout its supposed intent to bring meaningful cases, cases that matter to the investing public, rather than enforcing “foot faults,” as it has been accused of doing over the years. My own experience with FINRA...more
Way back in 2006, NASD issued Notice to Members 06-55, which tweaked the Sanction Guidelines to allow not just the size of the firm to be taken into consideration when determining the appropriate sanctions to be meted out,...more
On May 16, 2018, the Securities Exchange Commission (“SEC”) announced it had settled charges against a registered broker-dealer, its clearing firm, and its chief compliance and anti-money laundering (“AML”) officer brought...more
We previously warned that some individuals involved with arranging EB-5 investments may be required to register as broker-dealers (see "Immigrant Investor Program Raises SEC Broker Registration Issues" in the Summer 2014...more
Over the past several years, the Financial Industry Regulatory Authority (“FINRA”), the self-regulatory organization responsible for regulating every brokerage firm and broker doing business with the U.S. public, brought...more
On October 8, 2015, the Securities and Exchange Commission charged an investment adviser and a broker dealer for failing to maintain and enforce polices to prevent misuse of material non-public information. Without admitting...more
SEC-Sanctioned Trader Began Alleged Spoofing After Complaining About Spoofing by Others to NYSE - Eric Oscher and Briargate Trading, LLC, a company 50 percent owned by Mr. Oscher, agreed to pay an aggregate fine of US...more
In an environment where even the largest and most powerful corporations have fallen victim to data breaches, it can be challenging to fathom how to protect against the sophisticated and ever-evolving threat of cyber attacks....more
Highlights Areas of High Risk and Examination Priorities for Financial Industry Firms - On September 15, the U.S. Securities and Exchange Commission’s (SEC’s) Office of Compliance, Inspections and Examinations (OCIE),...more
On September 17, 2015, the SEC announced charges against several senior executives of Penson Financial Services Inc., once the second-largest clearing broker-dealer in the country, and its parent corporation, Penson...more
Reflecting increased regulatory willingness to discipline principals and supervisors, FINRA recently announced that it had imposed an industry bar on the former president of a defunct broker-dealer, along with five registered...more
A recurrent theme in today’s enforcement environment is parallel and often overlapping proceedings. That is the case with a District of Columbia based broker that drew sanctions from the SEC, FINRA and DC. In the Matter of...more
FINRA’s newly revised Sanction Guidelines, effective immediately, signal that the upward trend in sanctions against broker-dealers is likely to continue. The Sanction Guidelines, which establish the range of sanctions...more
CFTC Issues CME Group Report Card: Scores Generally Good But NYMEX and COMEX Directed to Continue to Enhance Spoofing Surveillance - The Chicago Mercantile Exchange Group found early presents under its Christmas tree...more