Doug Cornelius on compliance for private equity real estate
LPL Financial LLC, a dually registered investment adviser and broker-dealer, failed to follow its own anti-money laundering policies and procedures regarding its Customer Identification Program and ongoing customer due diligence obligations. The Securities and Exchange Commission and LPL settled on the charges and the $18 million penalty. What can we learn from the case? On … Read more »
The Office of Foreign Assets Control published new guidance specific to the securities industry on 11/06/2008: Opening Securities and Futures Accounts from an OFAC Perspective. A strong OFAC compliance program consists of procedures that are similar to those found in a brokerage firm’s Customer Identification Program (“CIP”). Firms should use risk-based measures for verifying the … Read more »