AML and OFAC – Will Your AML Program Stand Up to Scrutiny?

It was announced in early November 2016 that $215 million will be paid to New York state by Agricultural Bank of China for engaging in “intentional wrongdoing,” including masking possibly suspicious transactions, at its New York branch. The New York State Department of Finance stated that some transactions involved parties subject to U.S. sanctions.  Red… READ MORE

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Oyster Consulting (Bermuda) Presents AML Lecture: Designated Non-Financial Businesses & Professions

Oyster Consulting (Bermuda) Ltd. lecture focused on the Designated Non-Financial Businesses & Professions impacted by the 2016 Proceeds of Crime Amendment Oyster Consulting (Bermuda) Ltd Consultant Henry M. Komansky, J.D., presented another in his very popular series of lectures on 2nd November 2016 discussing the Designated Non-Financial Businesses & Professions impacted by the changes to… READ MORE

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Senior Investor and Vulnerable Adult Clients: Regulations and Best Practices to Keep Your Firm and Your Clients Protected

The challenge of diminished capacity presents a major risk to your clients and their families if they are not prepared. It also presents a risk to the firm if you are not aware of how to address these issues.  As the number of vulnerable investor exploitation claims grows, FINRA and the SEC have increased their… READ MORE

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SEC Form ADV Revisions – Performance Books and Records Retention

Whether it is part of your annual 206(4)-7 testing or a routine on your compliance calendar, making sure your records are in order is a basic requirement.  On August 25, 2016, the SEC adopted multiple amendments to Part 1A of Form ADV (“Form ADV”), which include amendments to the books and records rule under the… READ MORE

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Who’s Listening? Your Cybersecurity is Only as Good as Your Weakest Link

Yahoo! Another security breach is in the paper – from 2014. While you are changing your passwords and security questions/answers, consider that your firm’s information security is only as good as its weakest link – and the weakest link can be something small. Even as small as a wireless mouse or the Bluetooth piece sitting… READ MORE

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Branch Exams and Program Design

Branch exams are a critical part of every broker-dealer’s system of compliance and controls, and must address risk while ensuring your firm is complying with relevant rules and regulations.  Branch exams are more than just walking into a location and working from a standard checklist. Branch location types, business lines, products, firm changes and varying… READ MORE

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Oyster Consulting (Bermuda) Presents AML Audit/Sanctions Lecture

  Oyster Consulting (Bermuda) Ltd Consultant Henry M. Komansky, J.D., presented another in his very popular series of lectures on 7th September 2016 discussing the new requirement under the Bermuda Proceeds of Crime Amendment Act 2015 for AML audits as well as sanctions, with a focus on UK and Bermuda laws and regulations. On 1… READ MORE

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