FINRA’s recent AML focus and settlements with firms for AML related deficiencies has, in at least one case, led to extra client screening via Google searches. UBS took the unusual step of requiring sales assistants of U.S. brokers to conduct Google searches for red flags as part of setting up new customer accounts. While the…
On January 7, 2019, the NFA issued Notice I-19-01 to update its original interpretive notice regarding cybersecurity. The new amendment clarifies certain requirements for a CPO’s and CTA’s Information Systems Security Program (ISSP). Most firms adopted the original requirements in March 2016. Since then, the original NFA notice has been a best practice guide for…
The current government shutdown is having a wide-ranging impact on the ability for firms to interact with the SEC for registrations and fund launches, among other needs. According to Founder and President Amy Lynch, new firms that are trying to register with the SEC will face delays in that process. While many items that are…
The current Federal government shutdown has essentially halted the SEC’s ability to complete ongoing exams or start new ones. Founder and President Amy Lynch explains that OCIE’s process during a shutdown is to suspend non-emergency or routine exams because they are not considered mission critical. Ms. Lynch further states that without funding for examiners’ travel,…