By: Jeffrey Haber A multi-level marketing program is a relative of pyramid scheme. “[A] pyramid scheme is an illegal investment scam based on a hierarchical setup.”[1] In the classic pyramid scheme, “participants attempt …
By: Jeffrey M. Haber The Currency and Foreign Transactions Reporting Act, also known as the “BSA,” enacted in 1970, established requirements for record-keeping and reporting by banks and other financial institutions.1 …
By: Jeffrey M. Haber On June 11, 2024, the Securities and Exchange Commission (“SEC”) announced (here) that it charged the Chief Executive Officer and founder of the now-shuttered artificial intelligence …
By: Jeffrey M. Haber On May 3, 2024, the Securities and Exchange Commission (“SEC” or “Commission”) announced (here) that it charged audit firm BF Borgers CPA PC and its owner, …
By: Jeffrey M. Haber The federal securities laws impose recordkeeping requirements on registered investment advisers to ensure that they responsibly discharge their roles in the nation’s markets. The Securities and …
By: Jeffrey M. Haber On many occasions, we have written about Ponzi schemes that have been the subject of enforcement actions brought by, and/or settlements with, the Securities and Exchange …
By: Jeffrey M. Haber It’s been some time since this Blog has written about Regulation Best Interest (“BI”).1 See here.2 As a general matter, Reg BI requires a broker, dealer, …
By: Jeffrey M. Haber Self-reporting violations of the federal securities laws is an important part of the Securities and Exchange Commission’s enforcement regimen. For decades, the SEC has credited cooperative …
By: Jeffrey M. Haber The objective of an auditor is to supervise the audit engagement, including supervising the work of engagement team members so that the work is performed as …
By: Jeffrey M. Haber The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), enacted on July 21, 2010, amended the Securities Exchange Act by adding Section 21F-17, “Whistleblower …
