By: Jeffrey M. Haber Two weeks ago, this Blog wrote about an enforcement action involving an investment adviser’s former co-chief investment officer who had been charged with running a more than …
By: Jeffrey M. Haber It has been some time since we have examined cherry-picking – a practice that can be an effective way to generate returns as well as a …
By: Jeffrey M. Haber The Bank Secrecy Act (“BSA”) and implementing regulations promulgated by the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) require that broker-dealers file a suspicious activity report …
By: Jeffrey M. Haber On November 8, 2024, the Securities and Exchange Commission (“SEC” or “Commission”) announced (here) that it settled charges against Invesco Advisers, Inc., which operates Invesco mutual …
By: Jeffrey M. Haber Artificial intelligence (“AI”) is everywhere. A person cannot watch television, listen to a podcast or read a newspaper without hearing about AI. As a new and …
By: Jeffrey M. Haber “Spoofing is a type of scam in which criminals attempt to obtain someone’s personal information by pretending to be a legitimate business, a neighbor, or some …
By: Jeffrey M. Haber As a general matter, “[a] cross trade is a practice where buy and sell orders for the same asset are offset without recording the trade on …
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 …
