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Identity Theft – Next Regulatory Frontier?

  ♦SEC Action signals End of Identity theft Complacency♦ A cease-and-desist order along with a $1 million fine suggests that the Securities and Exchange Commission is getting serious about enforcing the identity theft prevention rules it adopted jointly with the Commodity Futures Trading Commission five…
Charlie Frank
October 11, 2018
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All the Right Reasons to Use Exchange Analytics Training

  ♦Our Training Value Proposition♦ We have received a few phone calls asking us whether the FIA’s Safeguarding Customer Funds course is competing with our Customer Protection Rule course. The answer is yes. But we’ve always believed competition is a good thing, because it encourages…
Charlie Frank
October 2, 2018
News

A Close Look at a Spoofing Acquittal

  ♦Verdict: Not Guilty♦ The recent federal court acquittal of Swiss trader Andre Flotron is a notable event in light of the avalance of indictments, convictions, fines and settlements for spoofing. Attorney Clifford Histed and colleagues at K&L Gates detail the Flotron saga in a…
Charlie Frank
August 21, 2018
News

New Video

  ♦It's Just Cheaper on the Front End♦ In a new video, former Federal Prosecutor Renato Mariotti cuts to the chase on compliance training: “It’s just cheaper on the front end to make sure that your employees are following the rules, rather than have to…
Charlie Frank
August 8, 2018
News

#1 Question We’re Asked

  ♦Who Needs What, and When?♦ Who is required to take Anti-Money Laundering and Cybersecurity compliance training? We're asked that question a lot. If ongoing training for your firm is mandated, it's simply not enough to train your brokers and APs. Anti-Money Laundering Training: NFA-member…
Charlie Frank
July 18, 2018
News

When Supervision is Less Than Super

  ♦The ABCs of the AlphaBit Settlement♦ "It shall be an offense for any party to fail to diligently supervise its employees and agents in the conduct of their business relating to the Exchange." -- CME Rule 432.W That rule led to a disciplinary action…
Charlie Frank
July 9, 2018
News

A “Cautionary Tale” About Post-Execution Allocations

  ♦Don't Overlook Post-Execution Allocation Rules♦ Attorneys Liz Lyons and Mitch Goldberg call it a "...cautionary tale for Futures Commission Merchants, and other registrants, about the importance of training, updating supervisory procedures, and appropriately maintaining records." Last month's CFTC and NFA enforcement decisions against X-Change…
Charlie Frank
June 25, 2018
News

Market Conduct Can’t Be “Check the Box” Training

  ♦Spoofing, Surveillance, Supervision, Training♦ Training on spoofing and other disruptive trading practices "... cannot be 'check the box' training. The programs need to be strong and periodically assessed and updated as this area of the industry evolves." That's the conclusion of attorneys James Lundy…
Charlie Frank
June 18, 2018