No Password Required: An FBI Special Agent's Journey from Submarines to Anti-Corruption to Cybersecurity
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, the U.S. Securities and Exchange Commission (“SEC”) announced yet another wave of enforcement actions related to widespread “off-channel communications,” charging an additional 26 firms with failing to maintain...more
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
The Department of Justice (DOJ) has updated their Evaluation of Corporate Compliance Programs policy with special attention paid to messaging platforms when detecting and investigating potential misconduct and law violations....more
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
SEC Advertising Rules – Client Resource Center - November 4 was the compliance date for the new rule governing advertising and solicitation activities by investment advisers. The new rule substantially revises decades old...more
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
Recent Enforcement Action - The requirement that financial firms preserve books and records is nothing new. But how do such firms keep track of employees’ communications on applications like Signal or WhatsApp? Those...more
The SEC and CFTC recently charged 11 large financial institutions and their affiliates for failing to collect, monitor, and preserve communications over WhatsApp and other messaging services. These settlements follow a...more