Entries By morrie

Home / Articles posted by Morrie Simkin (Page 2)

About morrie

17
Jul
2018
Punished by the SEC? Supreme Court You Get Another Chance
WHAT?
Posted On July 17, 2018  By Morrie Simkin  And has No Comment

The Supreme Court, in Lucia v. Securities and Exchange Commission, ruled that the Administrative Law Judges (ALJs) hired by the SEC were not constitutionally appointed. The Court then said that anyone sanctioned in an SEC administrative proceeding where they objected to the ALJs powers could have […]

Read More

22
Jun
2018
FINRA PROPOSAL REDUCES BROKER’S OBLIGATIONS BUT EXPANDS OTHERS
Posted On June 22, 2018  By Morrie Simkin  And has No Comment

FINRA has solicited comments on its proposal to replace Rules 3270 (0utside Business Activities) and 3280 (Private Securities Transactions) with a new rule, Outside Business Activities (3290). The proposal reduces some of the reporting and supervisory duties imposed by Rules 3270 and 3280. Given this, it […]

Read More

11
May
2018
BROKERS MUST UPDATE AML COMPLIANCE MANUAL AND ANNUAL AML REVIEW
Posted On May 11, 2018  By Morrie Simkin  And has No Comment

Why: FINRA has amended Rule 3310, The Anti-Money Laundering Compliance Program. It now requires brokers to include in their AML Compliance Manual the duties imposed by FinCEN’s Customer Due Diligence Rule. It also requires, as part of the annual independent party review of their AML program, […]

Read More

27
Apr
2018
BROKERS BE AWARE OF YOUR CUSTOMER TRADES OR BE SANCTIONED
Posted On April 27, 2018  By Morrie Simkin  And has No Comment

What? The Legal Entity Beneficial Ownership Rule adopted by Treasury Department’s Financial Crimes Enforcement Network is part of an expanded anti-money laundering program. When opening an account for a legal entity the broker must understand the nature and purpose of the customer relationship. With this understanding […]

Read More

8
Apr
2018
Suspicious Activity Reports Can be A Broker’s Best Friend
Posted On April 8, 2018  By Morrie Simkin  And has No Comment

The SEC and FINRA recently sanctioned a firm and its principals including its anti-money laundering compliance officer for failure to file Suspicious Activity Reports (SARs). The firm was fined $750,000 by the SEC and $550,000 by FINRA. Yet, if properly used filing SARs can be a […]

Read More

23
Dec
2017
Follow FINRA Rule 2165 and Be Sued
Posted On December 23, 2017  By Morrie Simkin  And has No Comment

Morrie Simkin December 2017 FINRA has adopted Rule 2165 that is intended to protect individuals from financial exploitation; however, brokers need to be aware that following the rule may invite a law suit. Fortunately, there are some ways that brokers can protect themselves. FINRA Rule 2165, […]

Read More


Page 2 of 2