Supervisory Controls Testing – Is Rule 3120 On Your To-Do List?

The beginning of the year is often a time for getting organized; reviewing and updating your firm’s compliance calendar to include FINRA’s required annual supervisory controls testing and reporting should be on your to-do list.  FINRA Rule 3120 requires broker-dealers to have in place a system of policies and procedures that annually test and verify… READ MORE

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

Attending the FIA Futures & Options Expo in Chicago

Oyster Managing Director Don Horwitz and Director Dean Pelos will be attending the FIA Futures & Options Expo in Chicago, October 18-20, 2016. During his thirty-plus years in the industry, Don Horwitz focused on assisting futures commission merchants (FCMs), broker-dealers, derivatives exchanges and their central counterparty clearinghouses (CCPs). He served as general counsel and/or chief… READ MORE

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

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