Superveillance: Producing Integrated Insights Into Conduct

By Gregory Breeze, Shaun Hurst & Robert Cruz As follow up on the earlier post that described the collision of supervision and surveillance as ‘Superveillance’, we want to dive deeper into key principles and attributes that firms should consider as they seek solutions that go beyond the boundaries of traditional supervisory and surveillance tools. As […]

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Recap: 2018 FINRA Annual Conference

Congrats to FINRA for once again running a tremendous Annual Conference. Terrific to once again catch up with clients, prospects, partners, and colleagues from around the industry.  This year’s conference was a milestone for us, our first as a joined team of Smarsh + Actiance. It was great to hear the very positive feedback and […]

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Superveillance: Tracking the High Risk Brokers

As the broker-dealer world descends on DC for the Annual FINRA Conference this week, I wanted to return to the discussion of FINRA’s new guidance on Heightened Supervision, first discussed here.  Specifically, I’d like to click into the final point: •“ Embrace content surveillance: uncovering high risk broker activities may very well exceed the limits of […]

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High Risk Brokers: Can You Uncover the Information Risk?

As the Annual FINRA Conference draws closer, FINRA continues to send signals of its enforcement priorities for the balance of 2018.  As a follow-on to its January Exam Priorities Letter  FINRA has just released Regulatory Notice 18-15 “Heightened Supervision” that would require firms to adopt heightened supervisory procedures for brokers with histories of past misconduct. Among its […]

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FCA Regulatory Priorities for 2018

On April 9, 2018, the UK’s Financial Conduct Authority (FCA) published its Business Plan for 2018/19 which highlights the key priorities for this year. This year’s priorities reflect the resources the FCA needs to prepare for withdrawal from the European Union (EU). Brexit is a key priority for the FCA as it seeks a smooth […]

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Regulatory Updates: Firm fined $1.3 million for supervision failures

The SEC and FINRA recently fined a brokerage firm $1.3 million for failing to supervise suspicious penny stock transactions. Last month, FINRA fined a firm $550,000 for “failing to have adequate supervisory and anti-money laundering (AML) programs tailored to detect ‘red flags’ or suspicious activity connected to its sale of low-priced securities”. Further, the SEC […]

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GDPR and Rogue Whistleblowers – Who is the Data Processor?

Several organisations have considered the effect of GDPR in the context of whistle-blowing and the steps required to investigate claims, but what are the implications when a whistleblower doesn’t follow set procedures and decides to take matters into their own hands? Under GDPR the responsibilities of data processors has been expanded. Previously, the Data Protection […]

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Communications Compliance Review in 2018: What All Firms Can Learn from Financial Services

The review of employee communications for possible compliance policy violations has never been more important – and more complex. The complexity is being driven by the adoption of new communications tools that offer richer, more dynamic, and more effective means of collaborating with embedded voice, messaging, and app sharing capabilities. The days of attempting to […]

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Regulatory Update: Former Equifax CIO Charged with Insider Trading – Texting at the Center of the Charges

The text message from the former Equifax CIO was a red flag: “Sounds bad. We may be the one breached.” Federal prosecutors charged a former Equifax chief information officer (CIO) with insider trading, for selling nearly $1 million in company stock before the public disclosure of the Equifax data breach. The former CIO of a […]

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