Category Archives: Standard of Care

Compliance, Enforcement, Standard of Care

Coordinated $80 Million AML Enforcement Action Highlights Breakdown Between Policy and Practice

April 28, 2026 Clifford E. Kirsch, Editor Leave a comment

Regulators continue to focus on AML programs that exist on paper but fail in practice, particularly in higher-risk trading environments such as microcap and over-the-counter markets.

On March 6, 2026, Financial Crimes Enforcement Network, the U.S. Securities and Exchange Commission, and Financial Industry Regulatory Authority brought coordinated enforcement actions against Canaccord Genuity LLC arising from significant anti-money laundering failures tied to its over-the-counter trading business.

The coordinated resolutions resulted in a $80 million total monetary settlement, including amounts payable to the SEC and FINRA. FinCEN also required additional remedial undertakings, including independent consultant review work.

To help you make sense of what this means for you and your clients, read the full article from our friends at SEC³ here.

Compliance, Enforcement, Regulatory, Standard of Care

Updates on SEC, OCC, FinCEN and more from FiSolve

April 10, 2026 Clifford E. Kirsch, Editor Leave a comment

FiSolve‘s April 10th weekly financial and regulatory news updates:

Read the full update here.

Enforcement, Standard of Care

SEC Enforcement Highlights Essential Compliance Lessons from Affiliated Loan Transfers

March 26, 2026 Clifford E. Kirsch, Editor Leave a comment

The SEC recently charged a private credit adviser for misleading representations during affiliated loan transfers, alleging negligent violations of anti-fraud provisions under the Advisers Act. The adviser had not reassessed loan values amid significant market stress, and settled with a $900,000 penalty. Despite reimbursing the affected fund over $5 million and improving disclosures, enforcement proceeded.

Key Takeaways for Advisers:

Valuation Methods Must Reflect Market Conditions: Advisers should ensure methodologies consider current markets, not just historical pricing.
Support Representations with Documentation: Valuation and arm’s-length certifications need robust analytical backing.
Examination Findings Can Trigger Enforcement: Practices around valuation, conflicts, and principal transactions remain regulatory priorities.
Private Credit Valuation Is Under Scrutiny: Internal asset transfers may receive heightened attention from regulators.

To help you make sense of what this means for you and your clients, read the full article from our friends at SEC³ here.