.... Findings The SEC enforcement actions discussed in the article demonstrate that broker-dealers and investment advisers must maintain and enforce compliance and supervision policies and procedures reasonably designed to detect and prevent violations of the securities laws. When firm personnel commit...

... LLP. 2018 2017 Ashurst LLP. Licensed re-use rights only Hong Kong Securities and futures commission (SFC) Policies and procedures Court of appeal Insider dealing Remedial orders On 9 November 2017, the Hong Kong Court of Appeal upheld the decision of the Court of First Instance...

... risks and providing considerations tailored to those risks, the Compliance Advisory can be used as a tool to aid dealers in developing and assessing effective compliance programs. Practical implications Dealers should consider reviewing their firm’s existing compliance policies and procedures...

... Wilmer Cutler Pickering Hale and Dorr LLP. 2017 2017 Wilmer Cutler Pickering Hale and Dorr LLP. Licensed re-use rights only Authentication Risk assessment Cybersecurity Policies and procedures New York State Department of Financial Services (NYDFS) Encryption On February 16, the New...

... for and responding to initial regulatory compliance examinations by the SEC and FINRA, and key considerations in reviewing municipal advisor policies, procedures and business practices in light of the evolving regulatory and marketplace landscape. Findings SEC and FINRA compliance examiner feedback points...

... risks and providing considerations tailored to those risks, the Compliance Advisory can be used as a tool to aid dealers in developing and assessing effective compliance programs. Practical implications Dealers should consider reviewing their firms’ existing compliance policies and procedures...

... regularly review and evaluate the sufficiency of current policies and procedures regarding disclosure controls and internal control over financial reporting. If not already in place, companies should establish a disclosure committee and implement a bottom-up disclosure process. Senior management should...

..., including: “Strong, explicit and visible support” for compliance policies by senior leaders Clear, written policies and procedures that are periodically reviewed to account for “evolving risks and circumstances” as well as other messages about compliance conveyed to employees “through in-person...

... an impending acquisition by a private equity firm to purchase stock in the target company. The broker-dealer settled charges of violations of the federal securities laws for failing to adequately establish, maintain, and enforce policies and procedures to protect against insider trading by employees...

... information was stolen, lost or exposed, resulting either from deliberate wrongdoing, an accident or negligence. Daniel A. Nathan can be contacted at: dnathan@mofo.com © Authors 2014 USA Securities and Exchange Commission (SEC) Broker-dealer Policies and procedures Cybersecurity...

... FINRA and the SEC have imposed significant sanctions against Firms when it has found inadequate cyber security policies and procedures. Practical implications – Broker-dealers should review the White House’s recent Framework for Improving Critical Infrastructure Cybersecurity and evaluate...

... – In light of the SEC's recently announced zero-tolerance policy and the fact that Rule 105 does not require intent on the part of the short seller to engage in a prohibited transaction, firms should provide training to their employees regarding Rule 105, develop and implement policies and procedures...