avoid the audit trap
TRANSCRIPT
against a large investment firm for systematic anti-money laundering compliance failures2
$17,000,000
fine for one of the world's largest brokerage firms for systemic reporting, books and records, and related supervisory violations1
$2.8 Million
against a large investment firm and $250,000 against a financial services firm for failure to establish policies and procedures necessary to determine the amount of commissions their clients were being charged when sub-advisers “traded away” with a broker-dealer outside the wrap fee programs2
$600,000
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data aggregation, and commissions processing tools from EAI.
Avoid the Audit Trap
FINRA filed about 1500 disciplinary actions, including...
CybersecurityAML (particularly with respect to
microcap companies)
Senior citizens (particularly with respect
to POAs and trusted contact persons)
Conflicts of interest with respect to
investment advisors
Using data analytics to analyze complex products and embedded
derivatives
Insider tradingAccounting
issues
Cybersecurity, including cyber-related disclosure failures
1 FINRA2 SEC3 Ze’-ev Eiger, “The SEC and FINRA Preview 2017 Enforcement Priorities at SIFMA’s C&L
New York Regional Seminar,” The BD/IA Regulator, November 11, 20164 Ibid.
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2016
fine for a major discount brokerage for significant failures in required electronic records and email retention1
$2.6 Million
2017
against three registered advisers for failures in their compliance programs2
$120,000
FINRA enforcement priorities include:3
The SEC will focus on:4
The SEC filed 868 enforcement actions vs. 807 in 2015, including...
2016
Don’t become another notch in regulators’ belts
Record data quickly, accurately and securely
Efficiently and automatically manage broker/dealer risk and liability across multiple business lines
Get a single-screen view of data aggregated from multiple systems.
Automatically red-flag non-compliant or unsuitable transactions for increased scrutiny and document compliance reviews at varying levels
Access tools to simplify regulatory compliance, AML compliance, and commissions processing.
Surviving audits isn't getting any easier