Blog
Identification of Politically Exposed Persons
Identification of Politically Exposed Persons (PEPS) is vital because due to their position and influence, many PEPs are in positions that potentially can be abused for the purpose of committing money laundering offenses, corruption, bribery and terrorist financing. As a firm, in order to comply with the requirements of monitoring [...]
Recent Revisions to MSRB Rule G-14
On May 22, 2015, the Securities and Exchange Commission (SEC) approved certain amendments to MSRB Rule G-14 related to transaction reporting, which became effective on July 18, 2016. MSRB Rule G-14 requires dealers to report all executed transactions in most municipal securities to the MSRB’s Real-Time Transaction Reporting System (RTRS) [...]
Private Equity and Finder Fees
We have all heard the stories about small or startup companies looking to raise capital and being approached by “finders” offering to help them to meet their goals. In exchange for such services, they only request 3% of the money raised by their investors. That’s not bad, right? Wrong. The [...]
FINRA Rule 2210: Communications
As should be expected, broker dealers are not free to communicate with the public, including retail and institutional investors, without restrictions. The regulation of communications with the public minimizes, although it does not eliminate, the chance that the public will be misled by a firm’s advertisements. FINRA Rule 2210 establishes [...]
Beneficial Ownership Requirements for Legal Entity Customers
On May 11, 2016, the Financial Crimes Enforcement Network (FinCEN) issued its final rules to strengthen the customer due diligence requirements for covered financial institutions. Broker-dealers are deemed a “covered financial institution” and therefore must comply with the new rules, which includes a requirement to verify the identity of certain [...]
New FINRA Clock Synchronization Standard
The Securities and Exchange Commission (SEC) has approved a new clock synchronization standard for computer clocks used to record events in NMS securities and OTC equity securities. The current FINRA standard is a one-second tolerance. The new standard – new FINRA Rule 4590 – reduces that tolerance to 50 milliseconds. [...]