ARTICLE
23 September 2019

Broker-Dealer Settles FINRA Charges For Delayed Disclosure Of Potential Employee Misconduct

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Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
A broker-dealer settled FINRA charges for delaying the disclosure of alleged employee misconduct. As summarized in the Letter of Acceptance, Waiver and Consent ("AWC"), the broker-dealer
United States Corporate/Commercial Law

A broker-dealer settled FINRA charges for delaying the disclosure of alleged employee misconduct.

As summarized in the Letter of Acceptance, Waiver and Consent ("AWC"), the broker-dealer was more than 60 days late in disclosing 89 fraud-related internal reviews or allegations over a six-year period. According to FINRA, the delayed disclosures were primarily the result of the firm not having an established supervisory system or written supervisory procedures for disclosing negative information on employees' Form U-5.

To settle the charges, the firm agreed to (i) a censure, (ii) a fine of $1.1 million and (iii) the implementation of supervisory systems outlined in the AWC.

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