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January 2016 Archives

Billions: Real-Life Applications of Scenarios Depicted on the Show

billions-blog Ep 1 2 SHOWTIME's new series Billions kicks off introducing us to hedge-fund titan Bobby "Axe" Axelrod and the head of Axe Capital who faces-off against his nemesis, U.S. Attorney Chuck Rhoades. While the show definitely has a flare for the dramatic, some of the scenarios depicted are an accurate reflection of the current securities industry. In this blog series, we will explore the legal regulatory issues as they appear in the show and address how relevant they may be to you and your firm.

First CCO Held Personally Responsible to go to Trial

Today, IAWatch revisited the case of Thomas Haider, a former CCO at MoneyGram, who was assessed a $1 million civil money penalty by FinCEN. In 2012 MoneyGram paid a $100 million dollar fine for fraud against its customers. In 2014, "FinCEN assessed a $1 million civil monetary penalty against Haider based on his alleged willful failure to ensure that MoneyGram (1) implemented and maintained an effective AML, and (2) filed timely SARs." This was the first time the government has tried to hold a Chief Compliance Officer personally responsible for their employer's failings. Haider's attorneys tried to have the case dismissed but the judge threw aside the arguments and the case is going to trial. This case illustrates that there is a regulatory expectation for Chief Compliance Officers to make a concerted effort to oversee all aspects of a firm's business and take appropriate steps to develop and maintain effective compliance programs. One way to help ensure that your internal controls are adequate is to have an independent firm conduct a mock SEC examination. Our clients find this extremely beneficial, particularly for reviewing complex compliance processes. JLG's team has years of experience in conducting mock SEC examinations. Our goal is to identify gaps and provide guidance on how to enhance areas within the compliance program, and particularly those which regulatory authorities focus on. For more information please contact Jacko Law Group, PC at info@jackolg.com or 619.298.2880.

FINRA 2016 Regulatory and Examination Priorities Letter

FINRA 2016 NEW ISSUES Grey(1)On January 5, 2016, FINRA published their 2016 Regulatory and Examination Priorities Letter (the “Letter”). Many of priorities discussed had appeared on previous examination priority letters. However, there were several notable new additions to this year’s Letter that warrant additional consideration. Below is a brief synopsis of some of the new issues specifically addressed by FINRA for 2016:

J.P. Morgan's Marketing Mishap

Are your Marketing Materials Compliant (1)In its latest press release, the SEC announced that J.P. Morgan’s (JPMS) brokerage business agreed to pay $4 million to settle the claim that they made false statements in their marketing materials and on their website. The incorrect materials were being used from 2009 to 2012. While they were identified by internal staff as being false on at least four occasions from 2009 to 2011, J.P. Morgan did not proactively correct the materials until 2012.
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