Carl Ayers
Gain ideas for your PTP's P&Ps from this sample policy
"Starting at the end of 2025, the final rules mandate that clearinghouses require their members clear any Treasury cash trades executed on an inter-dealer broker ...
"The corollary is that practicing a culture of compliance, including self-reporting, remediation, and affording Enforcement staff meaningful cooperation during an investigation, is the best way ...
Your chance to check out our hottest stories from November
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Paulson filed a SAR in which the narrative stated that in reviewing a request to approve margin trading for a client’s account. However, failed to ...
The didn't contain the information as required by FinCEN, such as the “five essential elements”—namely the “who, what, when, where, and why” of the suspicious ...
This SAR narrative failed to include all of the information required by FinCEN, including the time-frame of the suspicious trades; details about the trading, such ...
Remember that you have a compliance obligation to obtain an initial and an annual notice from these clients confirming that their SLOA instruction remains valid