From a practical perspective, the actions provide a clear indication of the record-keeping and supervisory expectations of the SEC and CFTC and offer insight into how firms can improve compliance efforts.
These enforcement actions against broker-dealers, swap dealers, and futures commission merchants, combined with $200 million in fines issued in December 2021, brings the total for record-keeping lapses to more than $2 billion.
Given that prior fines for record-keeping failures were in the seven-figure range, these penalties coupled with mandatory remedial actions, including the engagement of third-party compliance consultants, reflect a new regulatory reality.
‘Enforcement 40’ for 2020
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