Search results for: "paper compliance program"
No, the FCPA Is Not ‘Back’
Folks, we need to have a conversation about all these legal bulletins, marketing emails, and conference agendas declaring that enforcement of the Foreign Corrupt Practices is now somehow “back,” simply because the Justice Department released guidelines the other week explaining how it will consider FCPA enforcement from here forward. Snap out of it. FCPA enforcement…
Read MoreLessons on Effective Supervision
Radical Compliance rarely looks at corporate misconduct as obscure as a broker-dealer improperly trading in the market for U.S. Treasurys, but trust me on this: a FINRA enforcement action last week on exactly that issue does indeed offer the larger compliance community a few lessons worth learning. Let’s take a look. The broker-dealer in question…
Read MoreDanske Bank, Part II: Compliance Reforms
Today let’s continue to look at the settlement Danske Bank reached with the Justice Department earlier this week, for the huge money-laundering scheme that operated from the bank’s Estonia branch in the 2000s and 2010s. I’ve been reading the plea agreement in the case, and compliance officers have a lot to consider here. First, to…
Read More$2 Mill Fine for Weak Compliance
FINRA today hit broker-dealer firm Cantor Fitzgerald with a $2 million fine for sloppy compliance practices that lasted at least five years, in an enforcement action sure to warm a compliance officer’s heart. The offenses related to naked short selling, where an investor first borrows stock to sell at a high price, then buys it…
Read MoreFive Questions for SEC Nominee Jay Clayton
Let’s start with the obvious about Jay Clayton, the Trump Administration’s nominee to chair the Securities & Exchange Commission: barring some bombshell news, he’s going to be confirmed. The Senate Banking Committee will schedule a hearing for him soon, Democrats will posture, and then Republicans will push him through to run the SEC. So far compliance officers…
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