Carl Ayers
Consider your 'vulnerabilities' to being used for money laundering when crafting your P&Ps, including the investment products you offer, investment recommendations, distribution channels, intermediaries used ...
Be careful giving a CCO too many hats to wear. FinCEN warns 'multiple additional job duties' 'generally would not fulfill" the requirement to have an ...
The CFTC amends the portfolio requirement thresholds for a qualified eligible person and makes other technical changes
Advisers caught in a spate of enforcement actions over the new marketing rule, dissecting your coming AML obligations under FinCEN's new rules, lessons from recent ...
The SEC asserts Randolph Abrahams made numerous misstatements in newsletters shared with investors
A new enforcement action sends the message that any increase in fees constitutes a material change that needs to be disclosed
This is FinCEN's amendment to the Bank Secrecy Act to require IAs to develop and implement AML programs
In total, since 2018, Hi2 Manager violated the custody rule on 17 occasions
The firm advertised that it was rated a 'Top 12 Financial Advisor' by Barron’s when it actually was rated a 'Top 1200 Financial Advisor' by ...
The firm has recognized and disclosed various conflicts so it lacked a reasonable basis for believing it would be able to substantiate an ad that ...