Huckleberry FINRA and Life on the MissiSECippi: Mark Twain, FINRA, SEC, CFTC and NASAA Enforcement Actions (November and December 2021)

From Brian Rubin and Amanda C. Oliveira in this month’s column for NSCP Currents:

Samuel Langhorne Clemens, d/b/a Mark Twain, was the author of many outstanding (and often humorous) books and short stories that had good guys (e.g., Huck, Jim and Tom), bad guys (e.g., Pap Finn; the Duke and the Dauphin, who were the equivalent of the 19th century boiler room fraudsters), self-regulators (e.g., Aunt Polly and the Widow Douglas), an actual Judge (well, fictional, but you know what we mean) (Judge Thatcher, father of Becky), and sanctions (the Duke and the Dauphin are tarred and feathered – a bit different from being censured or ordered to cease and desist). In other words, his stories sound a lot like some of the securities enforcement cases we regularly read.

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NFTs: A New Mechanism for Money Laundering… Uh Oh!

On February 4, 2022, the United States Treasury Department released a report that indicated non-fungible tokens (“NFTs”), currently, one of the trendiest cryptocurrency structures, may become a new avenue for money launderers and other nefarious ne’er do wells.  Those interested in offering NFTs to the public may, ultimately, be required to inquire as to the purchasers of their NFTs.  However, in the meantime and in consultation with securities counsel, it may not be a bad idea to start knowing who your customer is now.

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SEC Charges Advisor and Dual-Hatted CCO Over Inadequate Disclosures About Fee Mark-Ups; Form CRS Violations Continue; Compliance Professional Development and Leadership Inspiration; Lessons Learned and Worth Reading for December 2021

Lessons Learned 

Worth Reading, Watching, and Hearing

SEC Withdraws No-Action Letters Related to Marketing Rule; Risk Alert Highlights Findings from Investment Company Examinations;

December Regulatory Updates from Cari Hopsfenperger at Foreside.

Topics include:

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Filing Deadlines and To-Do List for December 2021

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