Outside Counsel

Broker-Dealer Compliance in Era of Regulatory Pressures

, New York Law Journal

   | 1 Comments

Robert C. Gottlieb and Derrelle M. Janey discuss key points from the Brown Brothers Harriman case, where the private bank was fined a record $8 million for anti-money laundering compliance failures: compliance programs must be intensely active, living organisms that constantly "monitor," continuously "investigate," "ensure" that issues are reported and, once reported, have an adequate protocol for "updating" on the activity at issue.

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What's being said

  • James

    Great article, The amended Rule 17a-5 requires brokers and dealers not exempt from SEC Rule 15c3-3 to file a compliance report with its annually audited financial statements. I work with McGladrey and there‘s a very useful piece on this very topic that will interest readers, ‘New Reporting Requirements for Brokers and Dealers‘ @ https://bitly.com/1rQlXBT

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