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SEC fines non-US entities for unregistered cross-border brokerage and advisory activities

James Burns (Willkie Farr & Gallagher LLP, Washington, DC, USA)
Kimberly Beattie Saunders (Willkie Farr & Gallagher LLP, Washington, DC, USA)

Journal of Investment Compliance

ISSN: 1528-5812

Article publication date: 2 May 2017

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Abstract

Purpose

To explain a settlement involving a foreign financial institution, its non-US subsidiaries, and the US Securities and Exchange Commission (“SEC”) that reveals an SEC focus on policing the activities of foreign firms that reach into the United States and helps further define the scope of activities that require registration under the federal securities laws.

Design/methodology/approach

Provides insight into a recent area of focus for SEC regulators and introduces the potential regulatory implications for non-US firms with activities that reach into the United States.

Findings

Given the SEC’s current enforcement focus, it is critical that financial institutions take care to conduct their activities with an understanding of the regulatory requirements associated with the provision of brokerage and advisory services to US clients and customers including, for many firms, registration as an investment adviser, broker-dealer, or both.

Originality/value

Practical regulatory guidance regarding SEC registration requirements that may reach non-US firms from experienced financial services lawyers specializing in asset management.

Keywords

Citation

Burns, J. and Saunders, K.B. (2017), "SEC fines non-US entities for unregistered cross-border brokerage and advisory activities", Journal of Investment Compliance, Vol. 18 No. 1, pp. 75-77. https://doi.org/10.1108/JOIC-02-2017-0002

Publisher

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Emerald Publishing Limited

Copyright © 2017, Willkie Farr & Gallagher LLP