Monthly Archives: January 2018

FINRA’s Cook Wants to Stop Bad Actors

On Jan. 10, 2018, FINRA issued video of high-risk registered representative program. Discussion with Mike Rufino, EVP, Head of FINRA Member Regulation,—Sales Practice. Included overview of the program and criteria FINRA use to identify high-risk activity. With tools and resources which are available to help firms perform their own reviews.  
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U.S. CFTC Parts 3 and 9 Regulations

On Jan. 9, CFTC issued part 3, 9 regulation on market discipline. Integrate existing advisory guidance, incorporate swap execution facilities (SEFs), and update provisions currently applicable to designated contract markets (DCMs). CFTC Revisions Part 3 governs registration of intermediaries; while Part 9 details the rules related to CFTC review of exchange disciplinary, access denial, and other adverse…
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U.S. FINRA Exam Findings, Priority

On Jan. 8, 2018, FINRA issued regulatory and examination priorities letter for 2018. Resource for firms to enhance compliance, supervisory, risk management programs. Focus for 2018 on fraud, high-risk firms and brokers, operational and financial risks. Financial risk included technology governance and cybersecurity, market regulation. Sales practice if, recommend complex products to unsophisticated/at-risk investors. Protection…
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U.S. DoJ, SEC Och-Ziff Fraud, FCPA

On Jan. 3, 2018, DoJ charged Michael Cohen, for scheme to defraud charitable client.   When recommending investments in African mining sector, to a charitable foundation. Violated fiduciary duties to charity, by making misrepresentation, concealing conflicts. One mine seller, owed Cohen millions of dollars, on a delinquent $18mn personal loan. Cohen had made the loan…
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U.S. OFAC Human Rights Abusers

On Dec. 21, Treasury OFAC sanctioned 13 for abuse, corruption. Executive Order implemented global Magnitsky Human Rights Accountability Act. Executive action was taken on 13 serious human rights abusers and corrupt actors. OFAC, also imposed sanctions on an additional 39 affiliated individuals and entities. Yahya Jammeh Ex-President of Gambia 1994-2017 engaged in human rights abuses…
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