The firm's use of the letter was also improper because it required its clients, all of whom are retail clients, to agree to a waiver ...

Where red flags or 'high risk factors with respect to money laundering activities' were present, the firm didn't conduct the enhanced AML due diligence it ...

The Commission staff’s investigation found off-channel communications by Apollo personnel, including at senior levels. These communications were sent among colleagues as well as to external ...

Beginning in 2024, the Carlyle Group and its investment adviser affiliates began to roll out on-channel messaging platforms for external communications

Schwab provided its personnel with firm-issued devices or other firm-approved applications, making communications through approved channels more readily available, and disciplined personnel who violated its ...

An unauthorized third party fraudulently persuaded a Robinhood employee to download remote access software onto a Robinhood computer and give the actor control of the ...

These off-channel communications included records required to be preserved under the Advisers Act because they related to a recommendation made or proposed to be made ...

The adviser failed to implement sufficient monitoring to ensure that its recordkeeping and communications policies were being followed

The firm didn't have sufficient resources devoted to its compliance function to adequately review and address the suspicious activity identified by its surveillance systems

The compliance department did not collect the referenced WhatsApp messages from the partner