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Category Archives: Money Laundering

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What Do Insider Trading And Data Breaches Have In Common

Posted in Cyber-Security, Federal and State Criminal Activities, Insider Trading, Money Laundering, SEC Enforcement, Securities Fraud

It is bad enough that firms and publicly traded companies have to make sure that their respective IT architecture is safe and secure, but recent developments demonstrate that you have to be weary regarding the media outlet with who you share material, non-public information. The SEC and the DOJ in a joint effort have brought… Continue Reading

Suspicious Activity Reports, FCMs and IBs, Is That A Marriage Made In Heaven

Posted in CFTC Compliance, Compliance and Supervision, Money Laundering

Suspicious Activity Reports (SARs) have been a useful tool for financial institutions to report financial fraud while, at the same time, prohibiting the reporting institution from disclosing the existence of a SARs in response to a third-party request.  In 2010, the Financial Crimes Enforcement Network (FinCEN), amended this regulation to extend the prohibition against disclosure… Continue Reading

What Does FINRA Rule 3270 Mean To You

Posted in Broker-Dealer Regulation, Compliance and Supervision, FINRA Compliance, FINRA Enforcement, Money Laundering, Ponzi Schemes, Registered Representatives, Social Media

The outside business activities of registered persons have the potential for causing your firm significant liability, especially where those activities are unknown to the firm, involve firm customers and constitute a fraud.  FINRA 3270 only requires the registered person to provide notice to the firm before engaging in the activity, but should the firm do more.… Continue Reading


Posted in Money Laundering, SEC Enforcement

In its continuing enforcement onslaught on firms emanating from China, the SEC filed another action in the United States District Court for the Western District of Louisiana against a Chinese company.  The SEC alleged that the company mislead investors regarding its value in a variety of press releases.  Further, the SEC claims that a number of… Continue Reading


Posted in CFTC Compliance, CFTC Enforcement, JOBS Act, Money Laundering, SEC Compliance, SEC Enforcement, Securities Legislation

The SEC and CFTC launched a working group to discuss and identify money laundering vulnerabilities.  These issues have lingered for awhile.  Both agencies believe that there is an opportunity to clarify their positions relating to money laundering and if their programs could potentially uncover such events.  This group will also include representatives from the Treasury… Continue Reading