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Fallacy at the FERC

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After nearly a decade of watching the Federal Energy Regulatory Commission (“FERC”) enforcement staff fumble and bumble their way to ignominy, it is time to tell the real story of…

FINRA suspends London based Chief Compliance Officer

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Overview Laidlaw & Company, a U.K.-based independent investment banking and securities brokerage entered into a Letter of Acceptance, Waiver, and Consent (AWC) with FINRA on July 15, 2021. Also, party…

SEC affirms FINRA decision to fine CCO $5K.

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Late last year the Securities and Exchange Commission (SEC) released an opinion affirming a FINRA decision to fine a CCO for “failure to enforce WSP” (written supervisory procedures). The firm,…

JPMorgan Chase: Anatomy of a corporate investigation

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It is vitally important for the compliance professional to understand the methods and tactics used by various government agencies, both agencies with criminal prosecutorial powers as well as agencies with…

Former Vitol trader indicted on FCPA charges.

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In the first of what is thought to be many Foreign Corrupt Practices Act (FCPA) charges to be brought to the energy trading community, a former Vitol trader was indicted…

U.S. Supreme Court upholds SEC’s ability to use disgorgement, but with modifications.

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Overview At issue are three terms, equitable relief, disgorgement, and penalty. If one were to not burden oneself with defining terms and their context, the U.S. Supreme Court decided to…

Bitcoin and how not to be anonymous

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As crypto currencies become more prevalent people are starting to figure out that crypto currencies do not necessarily provide anonymity. Case in point Maksim Boiko a.k.a. “Gangass”. On March 27,…
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FinCen accesses a civil penalty of $450,000 against a former risk officer

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Overview On March 4, 2020 issued a settlement agreement with U.S. Bank’s former Chief Operational Risk Officer Michael LaFontaine whereby FinCen fined Mr. LaFontaine $450,000 and banned him from a…

Holding individuals accountable

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Overview The Department of Justice unsealed a 35-page indictment filed in February of 2015 against three individuals who were executives at Alstom S.A. (Alstom) and Marubeni Corporation (Marubeni) this week.…

CFTC charges a French national with manipulation

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On December 20, 2019 the Commodity Futures Trading Commission (CFTC) charged French national Christophe Rivoire with manipulation of U.S. dollar interest rate basis swaps during June and July of 2012.…