On Dec. 11, 2018 GE BaFin published the finalized version of the AML guidance. Interpretation and application instructions to the money laundering act (GwG). Implementing customer due diligence, internal safeguards, risk-based approach. Legal innovations, e.g. the concept of fictitious beneficial owner, are explained. Obligations in connection with identification of the person appearing are clarified. Interpretative…
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FINRA 2018 Report Exam Findings
On Dec. 7, FINRA issued second annual report on exam findings. Second annual report on examination findings, resource for firms from FINRA360. Follows 2017 report, highlighted cybersecurity, OBA, best execution. 2018 Report Observation from recent exams, selected for significance, frequency, and impact. Highlight exam findings on suitability for retail customers, fixed income mark-up disclosures, reasonable…
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BMA Suspicious Activities Reporting
On Dec. 6, BMA issued suspicious activities reporting requirement. Issued to confirm the reporting requirements for the Dec. 31, 2018 submission. All long-term insurers are required to complete the Schedule of Suspicious Activity Reporting and Sanctions (indicated in the BSCR model as SAR & Sanc.) Insurers that write in force direct long-term business are to…
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SEC International Insider Trading
On Dec. 6, SEC charged insider trading ring across three countries. Rajeshwar Gannamaneni gave information on impending mergers, acquisitions, and tenders to his wife, Deepthi Gandra, and father, Linga Rao Gannamaneni. Alleged Violation Gannamaneni was IT contractor, working at Singapore branch investment bank. Traded in account he controlled that was opened in the name of…
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NYDFS Fine Annuity Switches
On Dec. 5, NYDFS fined National Integrity $240k for annuities. National Integrity Life Insurance Company violation on annuity contract sales. Follows NYDFS Dec. 2016 guide on insurer annuity replacements. Disclosure on Switches Violated NY Insurance Regulations 187 and 60, on replacing annuity contracts. Immediate annuity provide periodic income payments beginning in 13 months. Deferred annuity…
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US IRS New Foreign Tax Credits
On Nov. 28, IRS, Treasury proposed rule on foreign tax credits. Follows 2017 Tax Cuts and Jobs Act (TCJA), legislation passed in December 2017. Foreign Credits Made major changes to internal revenue code, on how US taxes foreign activity. Proposed tax credits for businesses, individuals, to allocate, apportion expenses. Repealed fair market value method of…
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