Personal Devices and Messaging: Evolving Compliance Concerns and Best Practices
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
On August 14, 2024 the U.S. Securities and Exchange Commission (the “SEC”) announced settled charges against 26 SEC-registered investment advisers, broker-dealers and dually-registered broker-dealers and investment advisers...more
The Nutter Securities Enforcement Update is a periodic update of noteworthy recent securities enforcement activity, settlements, decisions, and charges. We provide brief summaries that highlight recent enforcement action...more
The SEC (U.S. Securities and Exchange Commission) recently hosted the 2024 SEC Speaks conference in Washington, DC. During the event, SEC leaders, including the Chair, commissioners, and senior staffers, shared their views...more
On February 9, the Securities and Exchange Commission (SEC) announced settlements with 16 firms relating to record-keeping violations stemming from off-channel communications totaling $81 million. The 16 firms were five...more
Artificial Intelligence (AI) is no longer just a buzzword, but a reality that is firmly on the radar of regulators and regulated firms in the US and UK. Recently, considerable investment into this area has prompted...more
I. The Phenomenon of Instant Messaging- Evolution and Proliferation- From basic platforms like IRC and AIM to globally dominant apps such as WhatsApp and Telegram, instant messaging (IM) has witnessed a radical...more
On September 29, the US Securities and Exchange Commission ("SEC") brought its latest wave of enforcement actions related to "off-channel communications," charging 10 additional firms with failing to maintain employee...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
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
In the last few weeks, several major U.S. financial institutions have disclosed to investors that the United States Securities and Exchange Commission (“SEC”) and/or the Commodities Future Trading Commission (“CFTC”) are...more
If you’re a regular reader of Hanzo, we’ve probably already convinced you that you need to be archiving any social media profiles that your organization maintains, along with your website. Chances are you’ve heard us talk...more
WARCs? WORMs? Is this a lost installment of the Lord of the Rings? Unfortunately, no. Rather, WARC and WORM are abbreviations that you should be familiar with if you’re maintaining digital archives for regulatory compliance,...more
Remember when nothing terribly important happened on social media? When Facebook was just a silly diversion where twenty-somethings could let their friends know what they were up to? For better or for worse, those days are...more
Do your web archives have inTegrity? There’s a trend today toward more interactive and personalized web content, but that makes online archiving technically challenging. In the financial services industry, FINRA and SEC...more