Failure to supervise

Concerns expressed by both compliance and trading desk about a new account opening fell on deaf ears

Should you have a need to supervise IARs, you can benefit from the aftermath of this case

Seven-month delay in reviewing OBA request and subsequent lack of communication on disapproval decision costs B-D $180K

The Commission staff’s investigation uncovered pervasive off-channel communications at all seniority levels at Cantor. The staff requested off-channel communications data from a sampling of more ...

The federal securities laws impose recordkeeping requirements on broker-dealers to ensure that they responsibly discharge their crucial role in our markets. The Commission has long ...

The firm failed to maintain and preserve off-channel communications its employees sent and received related to the broker-dealer’s business, CGMI received and responded to Commission ...

In September 2021, the Commission staff commenced a risk-based initiative to investigate whether broker-dealers were properly retaining business-related messages sent and received on personal devices. ...

Goldman Sachs’s widespread failure to implement its policies and procedures that prohibit such communications led to its failure to reasonably supervise its employees

Jefferies’ supervisors, who were responsible for preventing this misconduct among junior employees, routinely communicated off-channel using their personal devices

An associate on a derivatives trading desk exchanged more than 2,500 messages with Morgan Stanley colleagues, including several managing directors. The associate also texted with ...