Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast
Recent Developments in Anti-Money Laundering - The Consumer Finance Podcast
Investment Management Update – Exit Strategies
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
IIn this issue of our monthly Securities Enforcement Roundup, we highlight top securities enforcement developments and cases from November 2024. In November 2024: The US Court of Appeals for the DC Circuit issued a decision...more
The Financial Industry Regulatory Authority (FINRA) published guidance* to remind parties, attorneys, arbitrators, and mediators that the unauthorized disclosure of a Suspicious Activity Report (SAR) is a violation of federal...more
The Paycheck Protection Program (“PPP”) emerged as a lifeline for small businesses grappling with the unprecedented challenges of the COVID-19 pandemic. Lenders navigated a landscape of regulations that Congress quickly...more
In a series of settlements announced this year, the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) penalized several broker-dealers for allegedly failing to file...more
Financial services companies, such as banks, credit unions, lenders, finance companies, loan servicers, broker-dealers, and securities firms, often receive subpoenas from parties in litigation involving their customers,...more
Garcia Case Highlights Necessity of Knowing Your Customer and Listening to Internal Fraud Watchdogs. The SEC’s recent Order against a broker-dealer (the “Firm”) imposed a $750,000 financial penalty for the Firm’s failure...more
For the past decade, anti-money laundering (“AML”) has been at the forefront of securities regulators’ priorities. Indeed, AML enforcement cases have resulted in some of the highest fines imposed by securities regulators,...more
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
The U.S. Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA) have each published their annual examination priorities for 2021, signaling areas of scrutiny that broker-dealers should...more
This month’s coordinated U.S. multi-agency enforcement action against online broker Interactive Brokers (IBKR) signals authorities’ ongoing concerns about anti-money laundering/combating the financing of terrorism (AML/CFT)...more
Interactive Brokers LLC (“Interactive Brokers”) recently settled with three separate regulatory entities for a total of $38 million, without admitting or denying the findings. According to the SEC, Interactive Brokers failed...more
The Morgan Lewis Year in Review highlights key US Securities and Exchange Commission (the SEC or the Commission) and Financial Industry Regulatory Authority (FINRA) enforcement and examination developments, and cases...more
As we previously discussed, FINRA issued guidance to member firms and their associated persons in April 2020 to remain “vigilant in their surveillance against cyber threats and take steps to reduce the risk of cyber events.”...more
Last week, international regulators began issuing guidance and/or relief to impacted firms in response to the spread of COVID-19. The impact of this novel coronavirus has already begun materially to affect operations and...more
The Exam Priorities of the SEC’s Office of Inspections and Compliance or OCIE, announced on January 7, 2020 (the “Exam Priorities”), should be a key area of focus for every investment advisor and investment company. The Exam...more
On October 11, 2019, the leaders of the US Securities and Exchange Commission (SEC), the US Commodity Futures Trading Commission (CFTC), and the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a...more
The Financial Industry Regulatory Authority is not known for its aggressive enforcement record. But that may be changing. FINRA recently fined BNP Paribas for $15 million for anti-money laundering deficiencies in the...more
Enforcement actions sanctioning firms and, in a few cases, individuals for failing to investigate and report suspicious activity have been significantly on the rise. SEC, FinCEN, FINRA, and others have been active in this...more
On January 22, 2019, the Financial Industry Regulatory Authority (“FINRA”) issued its annual letter describing its current risk monitoring and examination priorities. See FINRA, Risk Monitoring and Examination Priorities...more
TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more
The SEC continues to reiterate the role of broker-dealers as “gatekeepers to the securities markets” by focusing on firms’ anti-money laundering (“AML”) obligation. The import that the SEC, as well as FINRA, places on firms’...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
Our Financial Services & Products Group examines a recent harsh Securities and Exchange Commission settlement for a broker-dealer and its chief compliance officer for failing to file suspicious activity reports....more
On May 16, 2018, the Financial Industry Regulatory Authority (FINRA) announced a $5.3 million fine on a financial services company (ICBCFS) for alleged systemic anti-money laundering (AML) compliance failures, including an...more