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Author: Susannah Hammond

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FINRA and SEC Set Out Supervisory Expectations on Communications Compliance

2024 isn’t even a month old and already two U.S. regulators have updated their expectations on communications compliance. Firms need to be under no illusions – recordkeeping is, and will remain, a key regulatory focus. Against a backdrop of $2.6bn+ fines…

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Enforcement Roundup – Regulators Remain Focused on All Aspects of Recordkeeping

What does the fining of a major Wall Street firm for trade surveillance failures, the holding to personal account of the CEO of a UK bank, the impact of cyber security incidents at a pair of broker dealers and another two…

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Top 5 Data Protection Tips For 2024

Top 5 Data Protection Tips For 2024 Data protection is, and will remain, a key priority for regulated firms and regulators alike and is an even greater focus in Data Privacy Week. For companies subject to multiple overlapping global privacy regimes,…

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The Failure to Capture Digital Communications Gets Personal

The last couple of years have been full of headlines not only of firms being fined for failing to capture digital communications but also of firms themselves taking action against employees for breaching internal policies on the use of unmonitored channels….

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From Voice to Email Communications – U.S Regulators Issue More Fines for Recordkeeping and Supervision Failures

An ‘unrealistic’ approach to communications compliance A U.S. introducing broker and swap dealer was fined $140,000 in October for failing to capture the required oral pre-trade communications under relevant Commodity Futures Trading Commission and NFA regulations. While the firm was aware…

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SEC Exam Priorities for 2024 Focus on Firm’s Ability to Evidence Compliance

The SEC exam priorities for 2024 give an essential insight into likely practices, products, and services which will be the focus of the Division of Examinations in the coming year. The priorities are those that pose emerging risks to investors or…

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SEC Risk Alert Reiterates Focus on Recordkeeping

The U.S. Securities and Exchange Commission’s Risk Alert provides additional information regarding the Division of Examination’s risk-based approach for both selecting registered investment advisers to examine and in determining the scope of risk areas to examine. It sets out the documents…

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Recordkeeping Enforcement Action Spreads to Brokers, Investment Advisers and Credit Rating Agencies

The U.S. Securities and Exchange Commission (SEC) and the Commodity Trading Futures Commission (CFTC) have widened their investigations and fined another series of firms for recordkeeping failures. As with previous recordkeeping breaches, the firms concerned failed to stop employees, including those…

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UK Energy Regulator Issues Its First £5.4m Fine for a ‘Failure to Record and Retain Electronic Trading Communications’

The UK Office of Gas and Electricity Markets (Ofgem) has, for the first time, used its powers to fine a firm over £5.4m for failure to record and retain electronic trading communications. Between January 2018 and March 2020 the firm did…

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If Conduct Risk Could Be the ‘New’ Prudential Risk – How Are You Monitoring It?

Regulators and policymakers around the world remain focused on culture and conduct risk. Indeed, Ian Johnston, Chief Executive of the Dubai Financial Services Authority, has gone so far as to suggest that conduct risk could be considered the “new” prudential risk….

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