On May 9, 2019, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN) issued “interpretive guidance” addressing how FinCEN’s money services business (MSB) regulations apply to
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William Mack
SEC Approves Final Regulation Best Interest, Form CRS
On June 5, 2019, the Securities and Exchange Commission (SEC) voted 3-1 to adopt a series of proposals intended to “substantially enhance” the standards of conduct for financial professionals.
First…
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FINRA Releases 2018 Annual Regulatory and Examinations Priorities
By William Mack on
Posted in FINRA, Technology
As it does every January, FINRA released its annual Regulatory and Examinations Priorities Letter identifying areas of examination focus for the coming year, recurring challenges faced by firms, and possible…
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Details on the CFTC’s New Self-Reporting Policy
By Jeffry M. Henderson & William Mack on
On Sept. 25, 2017, the Program on Corporate Compliance and Enforcement and the Institute for Corporate Governance and Finance at New York University School of Law hosted a policy speech
…
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SEC and FINRA Continue to Root Out Bad Brokers
By William Mack & Dale Rose Goldstein on
On Thursday, July 27, regulators and industry professionals gathered in Washington, D.C. to discuss the current regulatory environment, cybersecurity, and other hot topics at the SEC and FINRA’s 2017 National…
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FINRA’s 2017 Annual Regulatory and Examination Priorities
By William Mack on
Posted in FINRA
On Jan. 4, 2017, FINRA released its 12th annual Regulatory and Examination Priorities Letter in which it identifies its areas of examination focus for 2017, recurring challenges faced by firms,…
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SEC Charges Attorneys Across the Country for Acting as Unlicensed Securities Brokers
By William Mack on
Last week, the U.S. Securities and Exchange Commission (SEC) announced a series of enforcement actions against lawyers across the country, charging them with offering EB-5 investments and receiving compensation while…
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SEC Files a Complaint and TRO against Seattle Developer Alleging Misuse of EB-5 Funds
By William Mack on
Yesterday, the SEC filed a civil action and a motion for a temporary restraining order (“TRO”) against a well-known Seattle EB-5 developer. The SEC alleges, inter alia, that a developer…
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New FINRA Rule 2040 Becomes Effective
By William Mack on
Yesterday, the new FINRA Rule 2040 became effective. The rule was approved by the SEC earlier this year. Rule 2040(c) requires a broker-dealer who sells EB-5 securities to disclose to…
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SEC Charges two Businesses for Acting as Unlicensed Broker-Dealers in EB-5 sales
By William Mack on
Yesterday, the U.S. Securities and Exchange Commission (SEC) ordered a US-based foreign finder operation to cease and desist from operation as an unlicensed broker-dealer. The charges are some of the…
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