0      0

MON06 - Lessons Learned from Recent Enforcement Actions and CMPs

‐ Sep 23, 2019 11:45am

• Reviewing regulatory penalties for failure to develop appropriate, risk-based AML programs, systemic gaps such as lax CDD and non-remediation of existing consent orders

• Assessing SEC action involving transparency lapses such as misleading advisory clients on pricing and services and failure to disclose conflicts of interest

• Analyzing OCC actions requiring appointment and maintenance of compliance committees, director training on risk management practices and required look-backs