News & Analysis as of

Electronic Communications Enforcement Actions Financial Institutions

Ogletree, Deakins, Nash, Smoak & Stewart,...

Whistleblower Update: SEC, DOJ Still Focusing on Employment Agreements and Written Policies, Off-Channel Communications

The U.S. Securities and Exchange Commission (SEC) brought more actions targeting regulated entities for recordkeeping violations related to employees using noncompany communications platforms, and both the SEC and the U.S....more

Sullivan & Worcester

SEC and CFTC Continue Their Lucrative Pursuits of Penalizing Unapproved Communication Methods

Sullivan & Worcester on

SEC's and CFTC's Enforcement Actions Against Multiple Firms - In its continued pursuit of rooting out and penalizing broker-dealers and investment advisers for their failure to prevent unapproved communication methods, the...more

Ballard Spahr LLP

Blockchain Analysis and Related Expert Testimony Admissible In Criminal Trial

Ballard Spahr LLP on

It is challenging for law enforcement to track down and trace illicit activities conducted through digital currencies. The process can be very time- and resource-intensive. Further, securing charges and arrests, and...more

Thomas Fox - Compliance Evangelist

Messaging App Compliance in Regulated Industries: Lessons from Recent Enforcement Actions

In recent years, regulated industries, particularly broker dealer firms like Wells Fargo and Morgan Stanley, have faced increased scrutiny from regulatory bodies due to their lack of compliance in policing messaging apps. The...more

Zuckerman Spaeder LLP

Off-Channel Communication Risks: SEC and CFTC Enforcement Actions and Compliance Considerations for Financial Firms

Zuckerman Spaeder LLP on

In an increasingly digital world, financial firms need to be mindful of the variety of electronic communication channels that their employees use for work. Even where firms require employees to use firm-managed email networks...more

BCLP

A Time of Transition for the CFTC

BCLP on

Over the past year, the Commodity Futures Trading Commission continued moving its focus away from practices like spoofing, instead bringing high-profile actions in the crypto space and reaching significant settlements with...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With $1.1 Billion Penalty Deal, SEC Joins DOJ in Firing Warning Shot at Financial Services Industry About Outdated Employee...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

Cadwalader, Wickersham & Taft LLP

Eleven Financial Institutions Pay $700 Million to Settle Recordkeeping and Supervision Violations Related to Off-Channel Business...

On September 27, the Commodity Futures Trading Commission (“CFTC”) issued orders to settle charges against 11 major U.S. and international financial institutions and their swap dealer (“SD”) and futures commission merchant...more

Nutter McClennen & Fish LLP

Nutter Bank Report: October 2021

Federal and State Financial Regulators Publish New Guidance on LIBOR Transition - The federal banking agencies, the NCUA and the CFPB, in conjunction with the state bank and state credit union regulators, have issued joint...more

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