Policy Patty Toolkit 

Making the world a little more compliant one toolkit at a time.


The Policy Patty Toolkit Blog covers emerging issues on governance, risk and compliance controls.

This Blog is made available by the Policy Patty Toolkit for informational purposes only to cover emerging legal, governance, regulatory and compliance matters and issues. The postings are not intended to provide specific professional advice (legal, tax, or accounting) to an identified problem or issue. By using this Blog, you understand and acknowledge that there is no attorney-client relationship formed between us and should not use this site as a substitute for legal advice from your legal counsel regarding a particular matter or advice from another professional.

view:  full / summary

FINRA suspends former UBS broker who traded excessively in elderly clients' accounts

Posted on November 26, 2018 at 5:40 PM
FINRA suspended, David H. Fagenson, a former UBS Financial Services Inc. broker for eight months. Fagenson made a number of unsuitable trades in the accounts of three senior citizens, creating steep losses for the clients and generating hundreds of thousands of dollars in commissions and markups for himself and UBS. FINRA found that Fagenson's trading in the accounts of the three clients was "excessive and unsuitable" given the clients' ages and levels of risk tolerance, according to FINRA. Fage... Read Full Post »

DOJ Enforcement Actions - Week of November 19, 2018

Posted on November 25, 2018 at 3:30 PM
The Department of Justice took the following actions for the week of November 19th: November 22, 2018 Press Release Deputy Attorney General Rod Rosenstein Delivers the Keynote Address at the 87th INTERPOL General Assembly in Dubai, United Arab Emirates November 21, 2018 Speech Acting Attorney General Matthew Whitaker Delivers Remarks at John F. Kennedy International Airport???s International Mail Distribution Center Press Release Justice Department Obtains $11.3 Million Settleme... Read Full Post »

FINRA Reminds Firms of Exercise Cut-Off Time for Options Expiring on the Friday After Thanksgiving

Posted on November 22, 2018 at 12:05 AM
The national options exchanges are closing at 1:00 p.m. Eastern Time (ET) on Friday, November 23, 2018 (the Friday after Thanksgiving), which will modify the exercise cut-off time for expiring options. FINRA reminds firms that pursuant to FINRA Rule 2360(b)(23)(A)(viii), if a national options exchange or The Options Clearing Corporation announces a modified time for the close of trading in standardized equity options, then the deadline for an option holder to make a final decision to exercise or... Read Full Post »

SocGen Fined by NY's DFS for Economic Sanctions and AML Violations

Posted on November 20, 2018 at 6:50 PM
New York's Department of Financial Services (DFS) announced that it has entered into two consent orders with Societe Generale SA and its New York branch under which the bank will pay fines totaling $420 million for violations of laws governing economic sanctions and New York anti-money laundering laws. The order stems from a DFS investigation found that the bank executed billions of dollars in illegal and non-transparent transactions to parties in countries subject to embargoes or otherwise sanc... Read Full Post »

SEC Actions on November 16th and 15th:

Posted on November 19, 2018 at 4:25 PM

Bellow is an overview of actions taken by the SEC on November 16th and 15th:

Two ICO Issuers Settle SEC Registration Charges, Agree to Register Tokens as Securities
Nov. 16, 2018 

The SEC announced settled charges against two companies that sold digital tokens in initial coin offerings (ICOs). These are the Commission’s first cases imposing civil penalties solely for ICO securities offering registration violations. Both companies have agreed to return funds...

Read Full Post »

China Amends Its Anti-Corruption Law

Posted on November 15, 2018 at 8:25 AM

As reported in the FCPA Blog recently, China has amended its Criminal Procedure Law (CPL) to codify rules encouraging cooperation in government investigations, align with the new national supervision system, and introduce trials in absentia for certain crimes, including bribery and corruption. The amendments took effect immediately on October 26, 2018. 

Highlights of the changes include:

1. Codified leniency rules in criminal guilty pleas.

2. Revised procedures for inv...

Read Full Post »

NY Attorney General Announces Judgment Against Ithaca Auction House For Failing To Pay Over $230K To Consumers

Posted on November 15, 2018 at 8:15 AM

New York Attorney General Barbara D. Underwood announced a judgment obtained against Finger Lakes Estate and Auction, Inc. and its owner, Charles Dorsey, for fraudulently inducing consumers into giving up their personal property for auction sales and failing to return the proceeds as promised. The judgment requires Finger Lakes and Dorsey to pay $237,739 in full consumer restitution and $12,000 in civil penalties and costs, and retain a Trustee to handle all of the money from future auction s...

Read Full Post »

SEC Settles Insider Trading Claims Against Former Chairman and CEO of Advanced Medical Optics

Posted on November 14, 2018 at 1:20 PM

The SEC announced that it has agreed to resolve its insider trading claims against James V. Mazzo, the former Chairman and Chief Executive Officer of Advanced Medical Optics, Inc. (AMO) for allegedly tipping information about his company's acquisition to his close personal friend, former professional baseball player Douglas V. DeCinces. 

The SEC's complaint alleged:

  • In October 2008 Mazzo executed a nondisclosure agreement with Abbott Laboratories, Inc., as Abbott expl...

Read Full Post »

PR Firm and Publisher Settle FTC Allegations They Misrepresented Product Endorsements

Posted on November 13, 2018 at 2:35 PM

Two Georgia-based companies and their principals agreed to settle Federal Trade Commission allegations that, in connection with promoting a new insect repellent during the 2016 Zika virus outbreak, they misrepresented that paid endorsements were independent consumer opinions and commercial advertising was independent journalistic content.

Under two proposed Commission orders, the respondents are prohibited from making such misrepresentations going forward, and must disclose material con...

Read Full Post »

DOJ Enforcement Actions - Week of November 12, 2018

Posted on November 11, 2018 at 3:55 PM

The Department of Justice issued the following actions for the week of November 12th:

November 11, 2018

Press Release

Acting Attorney General Whitaker Statement on Veterans Day

November 9, 2018

Press Release

Third Real Estate Investor Pleads Guilty to Bid Rigging in Florida Online Foreclosure Auctions


Press Release

Two Residents of Lebanon Arrested in Seattle in Connection with Scheme to Illegally Export Firearm...

Read Full Post »