With limited amendments to its proposed rule, the Financial Crimes Enforcement Network (“FinCEN”), a division of the U.S. Department of the Treasury, recently promulgated its final rule (the “Reporting Rule”) implementing the...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
10/21/2021
/ Anti-Money Laundering ,
Consent Order ,
Enforcement Actions ,
Enforcement Priorities ,
Financial Industry Regulatory Authority (FINRA) ,
FinCEN ,
Investment Adviser ,
Know Your Customers ,
Petition for Writ of Certiorari ,
Risk-Based Approaches ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Suspicious Activity Reports (SARs) ,
Unregistered Brokers
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
6/7/2021
/ Anti-Money Laundering ,
Chief Compliance Officers ,
Compliance ,
Corporate Fines ,
Due Diligence ,
Enforcement ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Foreign Financial Institutions (FFI) ,
Internal Controls ,
Regulatory Violations ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
In a troubling recently-released Letter of Acceptance, Waiver and Consent (“AWC”), FINRA fined three Cetera Firms a total of $1,000,000 for failing to conduct the appropriate suitability review and to otherwise satisfy their...more