FINRA Unscripted

A broker-deal firm’s anti-money laundering efforts may overlap with any number of other regulatory concerns. On the last episode, we looked at the intersection of a firm’s AML and cybersecurity risks. On this episode, the second in a two-part series, we’re looking at how AML may overlap with a firm’s efforts to protect senior investors from exploitation and fraud.

Joining us on this episode are Jason Foye, a director with FINRA's Anti-Money Laundering Investigative Unit, and Brooke Hickman, a director with FINRA's Vulnerable Adults and Seniors Team (VAST), both with FINRA’s National Cause and Financial Crimes Detection Program. 

Resources mentioned in this episode:

FinCEN February 2011 Advisory on Filing SARs Regarding Elder Financial Exploitation

SARs on Elder Financial Exploitations: Issues and Trends, CFPB

DOJ’s Elder Justice Initiative

FINRA Resources on Senior Investors

FINRA Securities Helpline for Seniors

FINRA Foundation – Aging and Financial Decision Making 

FINRA Investor Alerts

Virtual Conference Panel: Social Distancing and the Impact on Older Investors

Virtual Conference Panel: Financial Crimes, Trends and Responses In the Midst of the Pandemic

Episode 33: Money Laundering in the Securities Industry

Episode 34: AML Priorities and Best Practices 

Episode 71: Anti-Money Laundering and Cyber Security 

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Firm regulatory risks and priorities don't exist in a vacuum. And that is perhaps nowhere clearer than when it comes to a firm's anti-money laundering responsibilities. A firm's AML risks can overlap with any number of other priorities. 

On this episode, the first of a two-part series, we're looking at the intersection of a firm's AML and cybersecurity risks. Joining us are Jason Foye, a director with FINRA's Anti-Money Laundering Investigative Unit, and Dave Kelley, a director with FINRA's Cybersecurity Specialist Program, both with FINRA’s National Cause and Financial Crimes Detection Program. 

Resources mentioned in this episode:

Episode 60: Introducing Greg Ruppert and the NCFC

Episode 33: Money Laundering in the Securities Industry

Episode 34: AML Priorities and Best Practices 

SWIFT: How Cyber Attackers ‘Cash Out’ Following Large-Scale Heists

FinCEN October 2020 Advisory on Ransomware 

FinCEN July 2020 Advisory on Cybercrime

FinCEN October 2016 Advisory on Cyber Events

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In the 30 years since the passage of the of the Americans with Disabilities Act, or ADA, there have been profound changes. But in this 30th Anniversary year, much remains to be done to advance the economic self-sufficiency of Americans with disabilities. 

Michael Morris’s research into and advocacy work around the financial security and capability of Americans with disabilities earned him the 2020 Ketchum Prize, the FINRA Foundation’s highest honor, which looks to recognizes outstanding service and research to advance investor protection and financial capability in the U.S.

On this episode, we talk to Michael Morris, the founder of the National Disability Institute, about his research, the intersection of race and disability, potentially impactful policy changes that have yet to be made and what leaves him feeling optimistic about the future.

Resources mentioned in this episode:

National Disability Institute

Keys to Financial Inclusion Podcast

Race, Ethnicity and Disability: The Financial Impact of Systemic Inequality and Intersectionality

Financial Capability of Adults with Disabilities

Webinar, October 14: The Extra Costs of Living with a Disability 

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For some investors, a high-volume trading strategy could be something they seek. For others, it might be a sign of "excessive trading.” But when does a lot become too much? What is a firm’s responsibility when it comes to supervising for this behavior? 

On this episode, Chris Kelly, deputy head of FINRA Enforcement and head of Main Enforcement and Sales Practice Enforcement joins us to talk about excessive trading or churning. He shares why this practice remains in focus for FINRA Enforcement and some recent trends. 

Resources mentioned in this episode:

Monthly Disciplinary Actions

Blog: Red Flags to Detect Excessive Trading

Investor Insights: 3 Ways to Guard Against Excessive Trading

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Technology is opening up new possibilities when it comes to solving business challenges. And that's important when it comes to optimizing an organization's most valuable limited resource: its people. 

On this episode, we hear from Member Supervision's new head of Data Analytics and Technology Kerry Gendron to learn how FINRA is augmenting its examination and risk monitoring program and teaching its employees the art of the possible.

Resources mentioned in this episode:

Episode 67: FINRA’s R&D Program

Episode 49: Exam and Risk Monitoring Program Transformation

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FINRA's Research and Development Program is using advanced analytics to change the way FINRA performs its essential regulatory functions. Feeding off FINRA’s culture of innovation, the R&D program is designed to be quick and agile, hoping to find transformative new technologies, but willing to fail and fail fast when an idea doesn't work out. 

On this episode, we hear from FINRA Technology’s Ivy Ho and Greg Wolff how the R&D program is pioneering the future of how FINRA fulfills its mission. 

Resources mentioned in this episode:

Episode 43: The Createathon

Episode 41: Introducing FINRA’s Values

Episode 36: Transforming the Digital Experience of Firms

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An ombudsman is a neutral party that acts as an impartial, confidential and independent resource that informally works to assist in finding solutions to issues or concerns an individual may have with an organization. And FINRA's Ombudsman is no different. 

On this episode, we sit down with FINRA's Ombudsman Cindy Foster to learn more about the office and how she works to prevent real or perceived conflicts of interest and, when necessary, recommend changes to ensure fair policies and procedures remain in place.

Resources mentioned in this episode:

Office of the Ombudsman

FINRA Audit Committee

International Ombudsman Association

United States Ombudsman Association

Investor Complaint Center

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When three hapless employees inadvertently embezzle a bunch of cash in the movie “Office Space,” they decide the best way to cover it up is to launder it. But the thing is, they don’t even really know what money laundering is and they learned that even the dictionary couldn’t fill them in.

If you want to understand what money laundering is, and more specifically, the efforts brokerage firms must take to prevent and detect it, stay tuned. We have something better than the dictionary: we have Blake Snyder and Jason Foye, two members of FINRA’s Anti-Money Laundering Investigative Unit.

On this episode of FINRA Unscripted, the first of a two-part series, Blake and Jason explain what money laundering is, how it looks different in the securities industry, how that makes regulation different for the securities industry, what FINRA’s Anti-Money Laundering Investigative Unit does and more.

Continue the conversation with part II. 

Resources mentioned in this episode:

Key Topics: AML

AML FAQs

AML Half-Day Seminars

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With the cancellation of the 2020 FINRA Annual Conference and other in-person events throughout the year, we’ve gone virtual with a variety of on-demand conference panels on regulatory hot topics. 

On this episode, we’re dropping in for a quick listen to the latest FINRA Virtual Conference Panel with FINRA CEO Robert Cook, Member Supervision Head Bari Havlik and Chief Legal Officer Bob Colby, moderated by Chip Jones, head of Member Relations and Education, as they talk about the continued impact of the coronavirus on firm and FINRA operations, recent conversations around racial justice in America and more. 

You can watch this full panel and nearly a dozen more on the FINRA website at any time.

Resources mentioned in this episode:

FINRA Senior Leaders Fireside Chat on Current Issues

COVID-19 FAQs

Regulatory Notice 20-16

Statement from the Board of Governors, June 2020

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As of June 30, 2020, the U.S. Securities and Exchange Commission’s Regulation Best Interest—or Reg BI—is officially in effect. That means brokerage firms now have to comply with a new standard of conduct when working with retail clients.

On this episode we talk to Meredith Cordisco and Jim Wrona of FINRA’s Office of General Counsel about what a post implementation date world looks like for FINRA member firms and what FINRA has been doing to train staff to ensure a consistent approach to examining around and enforcing the new rule across the organization.

And listen to the end for a special surprise from Jim. 

Resources mentioned in this episode:

SEC Reg BI Resource Page

FINRA Reg BI Resource Page

Virtual Conference Panel: Reg BI and Form CRS: Where Are We Now

Virtual Conference Panel: Reg BI: Compliance Inspections and Examinations

Email questions: [email protected]

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