Don’t miss the the AML Challenges panel at the 2018 FINRA Annual Conference on May 23, 2018 in Washington DC. FirstMark’s founder, Mitch Atkins, will present as a panelist. One of the key topics to be discussed is the FinCEN CDD Rule. The rule became fully effective May 11, 2018. If you’re ready, or even if […]
Yesterday FINRA settled yet another major case involving AML surveillance system deficiencies. This is one more in a series of cases in which FINRA has found that a broker-dealer’s electronic surveillance systems were insufficient to detect potentially suspicious transactions. In this case, FINRA fined the firm $13 million (which was duplicated by the SEC bringing […]
Mitch Atkins, founder and principal of FirstMark Regulatory Solutions, will present at the FINRA South Region Compliance Seminar in Fort Lauderdale, Florida on December 6, 2017. Mitch Atkins will present as a panelist on FINRA’s panel entitled Writing and Maintaining Written Supervisory Procedures. The panel will discuss the FINRA’s Supervision Rule (Rule 3110), and in […]
On Monday, December 5, 2016, FINRA announced yet another record fine against a broker-dealer for AML compliance failure. This action follows another just seven months ago in which FINRA fined a broker-dealer complex $17 million for AML compliance failure. There are numerous messages here which you can read about in my LinkedIn article that analyzes […]
AML compliance failures are starting to get the “zero tolerance” message from FINRA. It recently announced its largest fine ever against two firms for AML compliance failures, including the suspension of the AML compliance officer. Mitch Atkins, a former FINRA official breaks down this action in a LinkedIn article. In reality, these sanctions are not too […]
Last month in New York, I was invited to speak with a group of broker-dealer compliance staff at an event about email and social media compliance. More specifically, and to be technically correct, we call this “supervision of electronic communications” and you can read all about it in FINRA Rule 3110(b)(4). There, I had the opportunity […]
Compliance risks exist in your electronic communication. How will you effectively manage these risks? With the volume and velocity of information flowing through electronic communications channels, supervision has become a real challenge. Mitch Atkins presented at the Actiance Executive Briefing Series in New York on April 7, 2016 on how organizations can leverage their electronic […]
Mitch Atkins, founder and principal of FirstMark Regulatory Solutions, will present at the FINRA South Region Compliance Seminar in New Orleans, Louisiana on December 2 and 3, 2015. Atkins will present as a panelist on FINRA’s panel entitled, “Variable Annuities: Procedures, Practices and Findings.” The session is offered on both days, and the panelists will […]
Do you Update your Email Flagging Keywords? It is important to remember to periodically update your email flagging keywords if you use a monitoring system for electronic communications. Those systems, while powerful, are only as good as the dictionary of email flagging keywords used to call out a communication for review. Broker-dealers are required to […]
Check out the article written by FirstMark’s founder, Mitch Atkins, on LinkedIn summarizing the comments received in response to the FINRA Membership Application Rules Retrospective. This retrospective is a look back at the FINRA Membership Application Rules and further a request to the public for comment on what might be changed about the rules and […]
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