On Sept. 29, 2022, the Financial Industry Regulatory Authority (FINRA) released Regulatory Notice 22-20, alerting members to changes to the Sanctions Guidelines (Guidelines), effective immediately. The notice discusses changes varying from new fine ranges/minimums, additional guidelines, and non-monetary sanctions.

Continue reading the full GT Alert.

Tags: AML, anti-money laundering, economic sanctions, FINRA, GT Insight, regulatory
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Photo of Robert Long Robert Long

Robert Long previously served as a senior attorney at the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA), and as a federal prosecutor with the U.S. Department of Justice (DOJ). Rob defends clients in government investigations and prosecutions,

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Robert Long previously served as a senior attorney at the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA), and as a federal prosecutor with the U.S. Department of Justice (DOJ). Rob defends clients in government investigations and prosecutions, spearheads special investigations, and advises financial services firms and market participants on regulatory, compliance, and cryptocurrency matters.

SEC Attorney Experience

Rob spent over ten years at the SEC in various capacities—Trial Attorney, Branch Chief, Senior Counsel, and Staff Attorney. In the SEC’s Division of Enforcement, Rob led enforcement litigation in federal courts and administrative proceedings, and directed/conducted complex investigations that resulted in significant enforcement actions, including halting a $160 million Ponzi scheme, charging a Fortune 500 company with FCPA violations, charging a Fortune 1000 company with accounting fraud, and prosecuting multiple insider trading cases and sophisticated market manipulation schemes. Rob also served in the SEC’s Division of Market Regulation (now the Division of Trading and Markets) where he reviewed market rules and analyzed market structure issues. While at the SEC, Rob served in the SEC’s Fort Worth and Washington, DC offices.

FINRA Attorney Experience

As a Senior Regional Counsel in FINRA’s Department of Enforcement in Dallas, Rob investigated violations of FINRA, SEC, and Municipal Securities Rulemaking Board (MSRB) rules, and the federal securities laws. Rob successfully handled enforcement cases involving high-frequency trading, complex products, inadequate anti-money laundering (AML) compliance programs, due diligence violations, supervision failures, misrepresentations in oil and gas offering materials, unsuitable recommendations, net capital violations, and broker misconduct.

DOJ Attorney Experience

Rob is a former federal prosecutor. As an Assistant U.S. Attorney (AUSA) for the District of Arizona in the Economic Crimes and Public Integrity Unit and as a Special AUSA for the Northern District of Texas, Rob worked closely with various law enforcement agencies, such as the Federal Bureau of Investigation (FBI), Internal Revenue Service (IRS), U.S. Secret Service, and Postal Inspection Service, to prosecute high-profile white collar and public integrity cases. His cases included a 12 defendant mortgage and loan fraud scheme, a “politically sensitive” case of “extreme importance,” and an oil and gas offering fraud scheme that was included in The President’s Financial Fraud Enforcement Task Force. Notably, Rob was selected by the U.S. Attorney for the District of Arizona to participate in DOJ’s nationwide “Election Day Program” to respond to complaints regarding election fraud and voting rights abuses during the November 7, 2006 general elections, and was a member of the Mortgage Fraud Task Force.

National Practice

Rob draws on his knowledge of the inner workings of regulatory and law enforcement organizations and his wide-ranging multi-agency experience when defending regulatory and white-collar investigations and prosecutions; advising corporations, hedge funds, broker-dealers, investment advisers, and other market participants on compliance and regulatory matters; and conducting internal investigations. Rob advises clients on matters involving the SEC, FINRA, DOJ, FBI, Commodity Futures Trading Commission (CFTC), National Futures Association (NFA), Public Company Accounting Oversight Board (PCAOB), Financial Crimes Enforcement Network (FinCEN), Office of Foreign Assets Control (OFAC), and other federal and state regulatory agencies, including the Texas State Securities Board (TSSB). Rob is regarded as a skilled attorney advising companies (public and private), senior executives, boards, directors, and other individuals in securities enforcement and government investigation matters.

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Photo of William Mack William Mack

William B. Mack is a co-chair of the Financial Regulatory and Compliance Practice. He is experienced in advising companies on regulatory and compliance matters relating to the Securities and Exchange Commission regulations, the Exchange Act, Anti-Money Laundering laws and Financial Industry Regulatory Authority

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William B. Mack is a co-chair of the Financial Regulatory and Compliance Practice. He is experienced in advising companies on regulatory and compliance matters relating to the Securities and Exchange Commission regulations, the Exchange Act, Anti-Money Laundering laws and Financial Industry Regulatory Authority (FINRA) rules.

William’s practice involves all aspects of broker-dealer regulation, including Self-Regulatory Organization (SRO) membership, supervision, employment, research, soft dollar arrangements, chaperoning of foreign broker-dealers, social media, use of foreign finders, anti-money laundering rules, alternative trading systems (ATS), exchanges, and market making issues. He also provides regulatory guidance to investment banking clients in connection with securities offerings and related trading issues.

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