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All the Way to the Supreme Court

  ♦Spoofing and the U.S. Supreme Court♦ The first person convicted under the anti-spoofing provision of the Dodd-Frank Wall Street Reform and Consumer Protection Act has been denied a hearing by the United States Supreme Court, Gary DeWaal reported last week in his Bridging the…
Charlie Frank
May 31, 2018
News

NFA Sharpens Its Teeth on AML Deficiencies

  ♦NFA: AML Kid Gloves Are Coming Off♦ The National Futures Association is apparently taking a tougher stance on Anti-Money Laundering program deficiencies. Yesterday's Notice to Members I-18-11 puts FCMs and IBs on alert that failure to adhere to AML program requirements may result in disciplinary…
Charlie Frank
May 23, 2018
News

Who’s Left Holding the Bag? The FCM, of Course

  ♦Third-Party Vendor Blues♦ An FCM develops a robust Information System Security Program that requires assessment of potential vulnerabilities in its computer systems. The firm hires a third-party IT provider to conduct quarterly network penetration tests, vulnerability scans and firewall audits. The firm has the…
Charlie Frank
April 5, 2018
News

The New Mantra for Market Conduct Compliance

  ♦The Market Conduct Mantra♦ In a recent issue of his Bridging the Week newsletter, Gary DeWaal coined this mantra: "Training, training and more training -- and make it specific!" DeWaal, Special Counsel with Katten Muchin Rosenman LLP, was referring to the need for market…
Charlie Frank
March 31, 2018
News

When Regulators Come Knocking

♦CFTC Stance: "No Pause, No Letup"♦ In 2017, the Commodity Futures Trading Commission (CFTC) collected total monetary sanctions of more than $413 million. And according to CFTC Chairman Christopher Giancarlo, that aggressive pace is not about to abate. At an industry conference, Giancarlo said there…
Charlie Frank
February 20, 2018
News

AML Compliance Deadline is Looming

  ♦Are You Ready for the AML Compliance Deadline?♦ Mark your compliance calendar for May 11! That’s the date on which compliance with new FinCEN Anti-Money Laundering rules (published May 11, 2016) is required. This deadline is important to note even if your firm has…
Charlie Frank
February 5, 2018
News

The Anti-Spoofing Rule is Here to Stay

  ♦And so is the Firm's Responsibility to Detect and Prevent Infractions♦ When Clifford Histed was deputy chief of the Securities and Commodities Fraud Section of the U.S. Attorney’s Office, Northern District of Illinois, he supervised the office’s investigation and indictment in the landmark Michael…
Charlie Frank
January 9, 2018
News

Why Bother with Market Conduct Training?

  ♦Providing In-Depth Coverage♦ Market Conduct is an important component of the CFTC’s Statement of Acceptable Practices, however there are many other areas that a Futures Ethics course must address. With so much ground to cover, Ethics training can only provide a high-level overview of…
Charlie Frank
November 27, 2017