The document outlines significant fines imposed on large investment firms for various compliance failures related to anti-money laundering, reporting violations, and inadequate policies. It highlights FINRA's enforcement priorities, including cybersecurity and safeguarding senior citizens, alongside the increasing number of disciplinary actions. It emphasizes the need for firms to enhance their compliance processes to avoid regulatory pitfalls and streamline their operations.

1. against a large investment firm for
systematic anti-money laundering
compliance failures2
$17,000,000
fine for one of the world's largest
brokerage firms for systemic
reporting, books and records, and
related supervisory violations1
$2.8 Million
against a large investment firm and
$250,000 against a financial
services firm for failure to establish
policies and procedures necessary
to determine the amount of
commissions their clients were
being charged when sub-advisers
“traded away” with a broker-dealer
outside the wrap fee programs2
$600,000
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FINRA filed about
1500 disciplinary
actions, including...
CybersecurityAML (particularly
with respect to
microcap companies)
Senior citizens
(particularly with respect
to POAs and trusted
contact persons)
Conflicts of interest
with respect to
investment advisors
Using data
analytics to analyze
complex products
and embedded
derivatives
Insider trading
Accounting
issues
Cybersecurity, including
cyber-related disclosure failures
1
FINRA
2
SEC
3
Ze’-ev Eiger, “The SEC and FINRA Preview 2017 Enforcement Priorities at SIFMA’s C&L
New York Regional Seminar,” The BD/IA Regulator, November 11, 2016
4
Ibid.
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2016
fine for a major discount
brokerage for significant failures
in required electronic records
and email retention1
$2.6 Million
2017
against three registered advisers for
failures in their compliance programs2
$120,000
FINRA enforcement priorities include:3
The SEC will focus on:4
The SEC filed 868
enforcement actions vs.
807 in 2015, including...
2016
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