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Failure to supervise
In September 2021, the Commission staff commenced a risk-based initiative to investigate whether broker-dealers were properly retaining business-related messages sent and received on personal devices. ...
Goldman Sachs’s widespread failure to implement its policies and procedures that prohibit such communications led to its failure to reasonably supervise its employees
Jefferies’ supervisors, who were responsible for preventing this misconduct among junior employees, routinely communicated off-channel using their personal devices
An associate on a derivatives trading desk exchanged more than 2,500 messages with Morgan Stanley colleagues, including several managing directors. The associate also texted with ...
As a result, UBS’s recordkeeping failures likely impacted the Commission’s ability to carry out its regulatory functions and investigate violations of the federal securities laws ...
While permitting employees to use approved communications methods, including on personal phones, for business communications, NSI failed to implement sufficient monitoring to assure that its ...
Credit Suisse’s recordkeeping failures likely impacted the Commission’s ability to carry out its regulatory functions and investigate violations of the federal securities laws across these ...
These proceedings arise out of the widespread and longstanding failures of employees throughout the firms, including at senior levels, to adhere to certain of these ...
The analyst replied to Compliance Officer’s initial email, stating that he did not see anything that would require SARC to take immediate action, such as ...
BAG’s compliance manual included P&Ps requiring that trade orders include instructions for how the shares in the block trade are to be allocated. However, Brander ...