News & Analysis as of

Electronic Communications Securities and Exchange Commission (SEC) Commodities Futures Trading Commission

BakerHostetler

Deeper Dive: Preserving Ephemeral Messaging - Capture Data Before Its Ghosts Haunt Your Compliance

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Organizations whose mantra is “We just never delete anything” (i.e., organizations simply retaining all information indefinitely) are now facing headwinds, especially when the information contains personal information. As our...more

Sullivan & Worcester

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

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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

Alston & Bird

SEC and CFTC Rake In $474 Million in Fines for Off-Channel Communications, Rewarding Registrants That Self-Disclosed

Alston & Bird on

Two and a half years after the first major settlement with some of the world’s largest financial institutions, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) persist in their...more

Morrison & Foerster LLP

Significant Investment Adviser Regulatory Developments in 2024

Alongside the rapid pace of Securities and Exchange Commission (SEC) rulemaking, the SEC and its Staff continue to shape regulatory obligations for investment advisers in 2024 through guidance, alerts, enforcement actions,...more

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

SEC, Federal Regulators Target Employees’ Use of Text Messages, Off-Channel Communications

The U.S. Securities and Exchange Commission (SEC) and other financial regulators are targeting regulated entities over their employees’ use of personal messaging apps and other off-channel electronic communication platforms,...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

EDRM - Electronic Discovery Reference Model

Revolutionary Smartphone Data Collection Technology Helps Corporations Enforce and Comply with Regulatory Rules

The use of smartphones in the workplace is commonplace. Smartphones can offer many benefits to employees and employers, such as increased productivity, communication, collaboration, and flexibility. Hence, many companies...more

Jones Day

Considerations for Addressing DOJ’s Corporate Compliance Guidance on Mobile Devices and Messaging Platforms

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In light of the DOJ’s most recent guidance on the use of personal devices and third-party messaging applications by corporate personnel, this White Paper addresses issues and challenges that companies are facing in this area...more

Carlton Fields

Regulators Hit Jackpot: Off-Channel Communications

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Several years before announcing the first “off-channel” communications enforcement action, the SEC and FINRA cautioned broker-dealers and investment advisers about problematic record-keeping practices involving the use of...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

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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

BakerHostetler

SEC and CFTC Show No Signs of Slowing Down Enforcement Actions for Financial Firms’ Use of Off-Channel Communications

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The settlements announced by the SEC and CFTC on Monday are a continuation of the regulators’ focus on off-channel communications by employees of registered entities....more

Sheppard Mullin Richter & Hampton LLP

SEC Off-Channel Communications Sweep

Over the last several years, the Securities and Exchange Commission (the “SEC”) and the Commodities Futures Trading Commission (“CFTC”) have been laser-focused on the use of so called “off-channel communications” in the...more

BakerHostetler

SEC and CFTC Continue Crackdown on Financial Firms Over Off-Channel Communications

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The SEC and CFTC settlements with HSBC and Scotia Capital come after years of federal regulators’ and prosecutors’ steadily increasing scrutiny of off-channel communications. Anchoring these settlements are long-standing...more

Butler Snow LLP

What is the Message from Artificial Intelligence

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When announcing the much publicized $125 million fine against JP Morgan for violating recordkeeping rules, the U.S. Securities and Exchange Commission (“SEC”) Chair stated that financial institutions “did not act as if they...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

Lowenstein Sandler LLP

Material Investment Management Developments and Template Annual Compliance Checklists for Registered Investment Advisers, Exempt...

Lowenstein Sandler’s Investment Management Group is pleased to provide you with the summaries and checklists described below. Summaries of recent legal developments with respect to: •SEC’s 2023 Examination Priorities- ...more

J.S. Held

Off-Channel Communications: How Financial Services Organizations Can Address Regulators’ Latest Target

J.S. Held on

As a number of recent headlines demonstrate, the U.S. Securities and Exchange Commission (SEC) and other regulators have fined and penalized employers and employees in the financial services industry for non-compliance with...more

Perkins Coie

New DOJ Guidance on Personal Devices and Third-Party Messaging Applications Applies to Any Company DOJ May Scrutinize

Perkins Coie on

The U.S. Department of Justice (DOJ) recently released new guidance announcing several policy changes to further strengthen and clarify its approach to prosecuting corporate crime. The guidance, released through a memorandum...more

Katten Muchin Rosenman LLP

What's Up With WhatsApp? Regulators Recently Fine Firms $1.8 Billion in Aggregate for "Off-Channel" Communications

Recent alleged recordkeeping failures resulted in aggregate fines in excess of $1.8 billion levied against 11 Wall Street financial institutions and many of their affiliated entities by the Securities and Exchange Commission...more

Hanzo

Compliance Update: Unauthorized Messaging Apps Lead to 1.8B in Fines

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According to a recent press release from the Securities Exchange Commission (SEC), sixteen Wall Street firms were fined for widespread and longstanding failures by the organizations and their employees to maintain and...more

Foley Hoag LLP - White Collar Law &...

Companies Should Beware of Employees Texting Business Communications

Text messaging is convenient.  It is an informal and instant mode of communication now available through numerous apps, which allow an individual to use their synced phone, tablet, and computer to quickly fire off messages. ...more

A&O Shearman

SEC And CFTC Orders Concerning Electronic Communications

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On September 27, 2022, the SEC announced charges against affiliates of 11 financial institutions (15 broker-dealers and one investment adviser) for allegedly failing to maintain and preserve electronic communications and...more

Paul Hastings LLP

Ephemeral Messaging at the Office: Avoiding Pitfalls and Establishing Best Practices

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Users of ephemeral messaging applications may intend that their messages be—as the word “ephemeral” suggests—short lived, but the real-world consequences and legal ramifications from improper use of such apps can be anything...more

Robinson & Cole LLP

With $1.1 Billion Penalty Deal, SEC Joins DOJ in Firing Warning Shot at Financial Services Industry About Outdated Employee...

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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

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