Lara C. Thyagarajan

Oct 4, 2023 | lexology.com | Stephen Cohen |Ranah Esmaili |Lara Shalov Mehraban |Barry W. Rashkover |John I. Sakhleh |Lara C. Thyagarajan | +2 more

On September 29, 2023 — the last business day of its fiscal year — the U.S. Securities and Exchange Commission (SEC) issued the latest in a series of actions charging 10 firms with recordkeeping failures in connection with employees’ use of unapproved applications on personal devices to engage in communications relating to the firms’ business (known as “off-channel communications”).1 The firms charged included broker-dealers, investment advisers, and dually registered broker-dealers and...

Aug 2, 2023 | lexology.com | Paul Tyrrell |Stephen Cohen |Lara Shalov Mehraban |Lara C. Thyagarajan

The U.S. Securities and Exchange Commission (SEC) Division of Examinations (EXAMS) issued a risk alert entitled “Observations from Anti-Money Laundering Compliance Examinations of Broker-Dealers” on July 31, 2023.1 The risk alert focuses primarily on key observations identified by EXAMS where broker-dealers have not been meeting anti-money laundering (AML) regulatory expectations.