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5 W’s of the SAR Narrative
The Financial Crimes Enforcement Network (“FinCEN”) requires certain financial institutions to file Suspicious Activities Reports (“SARs”) in order to enable law enforcement to initiate or supplement major money laundering or terrorist financing investigations and other criminal cases. Financial institutions use the SAR to document and report suspicious or potentially suspicious [...]
Form ADV
Form ADV is the uniform form used by investment advisers that manage at least $25 million in assets to register with both the SEC and state securities authorities. The Form ADV is divided into 3 parts. Part 1 is a fill-in-the blank form that contains information about the investment advisory [...]
Filing A Suspicious Activity Report (“SAR”)
The Financial Crimes Enforcement Network requires certain financial institutions to file a Suspicious Activities Reports (“SAR”) to report suspicious transactions, as detailed in their FinCEN SAR Electronic Filing Instructions. This blog will go over some of the important aspects of filing a Suspicious Activity Report. […]
Message Archiving
An important component of financial compliance for broker-dealers is establishing message archiving for all communications relating to its business. Not only is it required by FINRA, but it can protect your Firm if there is an employee conducting unethical or illegal business activities. In a communication from Smarsh, a participant [...]
FINRA Notice 21-03: Low-Priced Securities Fraud
FINRA released regulatory notice 21-03, FINRA Urges Firms to Review Their Policies and Procedures Relating to Red Flags of Potential Securities Fraud Involving Low-Priced Securities, discussing issues with these securities offerings and fraud. Specifically, including those involving COVID-19 and cannabis related businesses, which appear to have been part of potential [...]
State Exemptions from Investment Adviser Registration GalleryState Exemptions from Investment Adviser Registration
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State Exemptions from Investment Adviser Registration
For an investment adviser to qualify for an exemption from state registration, they have to either meet an exemption under the Investment Act of 1940, be a federal covered adviser, or be registered with the SEC. The Dodd-Frank Act has created 3 thresholds for investment advisers based of their assets [...]