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|FINRA Is Ready to Lace-up and Focus on “Blocking and Tackling”: FINRA’s 2017 Priorities and Related Enforcement Actions|
Peter J. Anderson, Eric A. Arnold, Bruce M. Bettigole, Patricia A. Gorham, Olga Greenberg, Clifford E. Kirsch, Michael B. Koffler, Susan S. Krawczyk, Neil S. Lang, S. Lawrence Polk, Brian L. Rubin, Amelia Toy Rudolph, Sarah Razaq Sallis, Holly H. Smith, W. Scott Sorrels, John H. Walsh; Sutherland Asbill & Brennan LLP;
January 30, 2017, previously published on January 30, 2017As the football season was winding down, on January 4, 2017, the Financial Industry Regulatory Authority (FINRA) published its 2017 Annual Regulatory and Examination Priorities Letter.1 According to FINRA President and CEO, Robert Cook, this year’s 11-page letter focuses on “core...
|The FINRA WORM Turns|
Cynthia J. Larose; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
January 27, 2017, previously published on January 6, 2017It’s a new year, and time for the Financial Industry Regulatory Authority (FINRA)’s annual Regulatory and Examination Priorities Letter (the “2017 Letter”) We remind regulated entities of this list of examination priorities every year, because cybersecurity appears high on...
|European Account Preservation Order Regulation Comes Into Force|
Yiota Costa; Soteris Flourentzos & Associates LLC;
January 26, 2017, previously published on January 2017The EU Regulation No 655/2014 of 15 May 2014 (the “Regulation”) took effect as of 18 January 2016, establishing the European Account Preservation Order (“EAPO”) procedure. The purpose of the Regulation is to facilitate cross-border debt recovery in civil and commercial...
|Revised Cybersecurity Rules for New York’s Financial Services Industry|
Christopher W. Meyer; Whiteman Osterman & Hanna LLP;
January 26, 2017, previously published on December 30, 2016New York’s “first-in-the-nation” financial services cybersecurity rules moved one step closer to reality this week, with issuance of proposed revised rules by the Department of Financial Services.
|Legal Advice: Privilege - Royal Bank of Scotland (RBS) Rights Issue Litigation|
Peter Finding, Christina Morton, Libby Payne; Withers Bergman LLP;
January 18, 2017, previously published on January 10, 2017This case was not in substance about employment law, but it highlights a difficulty that any HR professional could encounter. It confirms that when lawyers are providing legal advice to a client on an internal investigation, the range of documents that is 'privileged' that is, immune from...
|Disclosure of Confidential Information within the Cayman Islands¿ Financial Services Industry - A Changing Landscape.|
Stuarts Walker Hersant Humphries;
January 18, 2017, previously published by Previously published on Stuarts Walker Hersant Humphries' website.The Government published The Confidential Information Disclosure Bill on 11 May 2016 which will come into force by September 2016. In doing so, it will repeal and replace The Confidential Relationship (Preservation) Law (2015 Revision) (“CRPL”) which some might say has been unfairly...
|New York Releases Revised Proposed Cybersecurity Regulations|
Frank J. Fanshawe, Joseph J. Lazzarotti, Rosemary McKenna, Damian J. Privitera, Damon W. Silver; Jackson Lewis P.C.;
January 17, 2017, previously published on January 9, 2017The New York State Department of Financial Services (“DFS”) has released a revised version of its proposed cybersecurity regulations, which set regulatory minimum standards for protecting the customer information and information systems of the financial services industry. The Revised...
|U.S Treasury Department Issues Guidance to Assist Financial Institutions in Reporting Cyber-Related Crimes.|
C. Phillip Buffington; Adams and Reese LLP;
January 17, 2017, previously published on December 22, 2016On October 25, 2016, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department issued an advisory that provides financial institutions with guidance on their obligations under the Bank Secrecy Act (BSA) to report cyber-enabled crimes. The advisory suggests that financial...
|Is It Safe? Limits of “Safe Harbor” for Temporary Holds on Senior Investor Transactions Under Proposed FINRA Rule 2165|
Bruce M. Bettigole, Clifford E. Kirsch, Sarah Razaq Sallis, Holly H. Smith; Sutherland Asbill & Brennan LLP;
January 13, 2017, previously published on January 12, 2017In addition to the recent increase in regulatory focus on senior investors,1 earlier this fall, the Financial Industry Regulatory Authority (FINRA) filed a rulemaking proposal (the filing) with the Securities and Exchange Commission (SEC) to adopt new FINRA Rule 2165 (Financial Exploitation of...
|FinCEN Issues Guidance to Casinos Confirming that Suspicious Activity Reports May Be Shared with U.S. Parents and Affiliates|
Mark A. Clayton, Carl A. Fornaris, Marina Olman-Pal; Greenberg Traurig, LLP;
January 12, 2017, previously published on January 6, 2017On Jan. 4, 2017, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN) issued guidance to casinos to confirm that, subject to certain limitations, a casino may, in accordance with the Bank Secrecy Act (BSA) and its implementing regulations, share a Suspicious...