On March 10, the European Parliament adopted a legislative initiative report detailing recommendations for a new directive on corporate due diligence and corporate accountability for holding companies accountable for harm caused to human rights, the environment and good governance (the Report).
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Sanction Guidelines
FINRA Releases Regulatory Notice on Revised NAC Sanction Guidelines
Posted in Broker-Dealer
On October 20, the National Adjudicatory Council (NAC) of the Financial Industry Regulatory Authority (FINRA) revised the Principal Considerations in Determining Sanctions section of the FINRA Sanction Guidelines to expressly contemplate a customer’s age or physical or mental impairment. In connection therewith, FINRA released Regulatory Notice 20-37.
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FINRA Issues Regulatory Notice Supplementing Prior Guidance on Credit for Extraordinary Cooperation
By Michael T. Foley, Leonard Licht & Susan Light on
Posted in Broker-Dealer
On July 11, the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 19-23 (the Notice) to restate and supplement prior guidance regarding the circumstances by which a firm or individual may influence the outcome of an investigation by exhibiting extraordinary cooperation. The Notice incorporates FINRA’s prior guidance and further clarifies how FINRA defines “extraordinary cooperation” and whether a potential respondent’s cooperation rises to such a level, as distinct from the level of cooperation expected of all member firms and their associated persons.
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