Journal of Investment Compliance: Volume 19 Issue 2

SEC 2018 examination priorities

Janet M. Angstadt, David Dickstein, Mark Goldstein, Richard Marshall

To analyze SEC Staff’s announced 2018 OCIE Examination priorities to provide insight to investment advisers and other regulated entities regarding areas of focus during SEC…

2017-2018 SEC whistleblowing review: insights and trends

Deborah Meshulam, Louis Ramos, Benjamin Klein

The purpose of this review is to unpack 2017-2018 US Securities and Exchange Commission (SEC) whistleblower developments and trends.

SEC’s Division of Investment Management voices concerns over registered funds investing in cryptocurrencies and cryptocurrency-related products

Vadim Avdeychik, Justin Capozzi

This paper aims to provide an overview of recent US Securities and Exchange Commission (SEC) Division of Investment Management staff (“Staff”) guidance related to investment funds…

Five crypto-securities trends that spell more lawsuits in 2018

William K. Pao, Eric Sibbitt, Taylor R. Evenson, Andrew J. Weisberg

The purpose of this paper is to identify trends in the unfolding wave of crypto-securities cases targeting initial coin offerings and discuss the reasons why these suits will…

SEC Enforcement: Self-Reporting Share Class Selection Disclosure Initiative

Elaine Greenberg

This paper aims to explain the U.S. Securities and Exchange Commission’s (SEC’s) recent Share Class Selection Disclosure (SCSD) Initiative, which offers potentially favorable…

FINRA’s disciplinary actions in 2017: increased restitution ordered with minimal changes in number of cases

Brian Rubin, Adam Pollet

The purpose of this paper is to analyze the Financial Industry Regulatory Authority’s (FINRA) 2017 disciplinary actions, the issues that resulted in the most significant fines and…

UK FCA adopts changes to rules governing availability of information for IPOs

Mark S. Bergman, John J. Satory, Sofia D. Martos

This paper aims to summarize new disclosure and procedural rules and related guidance for initial public offerings in the UK that will become effective on July 1, 2018.

AML and politically exposed persons: “good practice” recommendations from the Bank of Italy for policies and procedures to be implemented

Francesco Falco

The purpose of this paper is to provide guidelines and inputs for the implementation of policies and procedures governing transactions and business relationships with politically…

Insider dealer or unknowing participant: HK court of appeal confirms SFC’s broad powers to pursue insider dealing and fraud offences

Gareth Hughes, James Comber, Emily Austin

The purpose of this paper is to provide an overview of a recent Court of Appeal case regarding the Securities and Futures Commission’s (SFC’s) powers to seek remedial orders with…

Is your anti-money laundering program ready for FinCEN’s Customer Due Diligence Rule?

Rick Kuhlman, Jeff Ziesman, Carolyn Browne, Jason Kempf

The purpose of this paper is to bring broker-dealers’ attention to the upcoming deadline for compliance with the Financial Crimes Enforcement Network’s (FinCEN’s) final rule on…