Broker-Dealers Cross Into FCPA Territory

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1 Response

  1. Kevin L. Warmack, E.J.D. says:

    This is very much a case where the firm likely didn’t have the policies and procedures in place for a situation just like this and where the Compliance Officer didn’t do enough to prevent this from occurring. Although FINRA had provided some FCPA guidance through Regulatory Notices because of the relationship with a foreign bank or foreign entity, everything in the dealings should have been looked at with tighter scrutiny from both an AML perspective and an FCPA perspective.

    As the saying goes “You can pay me now or pay a lot later!!”