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- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By Aaron Nicodemus2023-11-08T20:10:00
A New York state law that takes effect next year will make it more difficult for registered investment advisers (RIAs) in the state to conduct proactive testing for violations of their firms’ off-channel communication policies.
The law, A836, signed by Gov. Kathy Hochul on Sept. 14, prohibits an employer “from requesting or requiring that an employee or applicant disclose any username, password, or other means for accessing a personal account through specified electronic communications devices.” The law takes effect 180 days after passage, in March.
The law contains a carve-out for entities that are required to monitor or retain employee communications “under federal law or by a self-regulatory organization,” and there lies the rub for RIAs. While all communications by broker-dealers are required to be monitored and retained by federal securities law, only communications that specifically deal with investment advice are required to be monitored and retained by RIAs.
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2023-11-16T17:00:00Z By Aaron Nicodemus
Establishing a set of policies and procedures to prevent employee use of nonauthorized electronic communications to conduct business is relatively straightforward. The hard part is monitoring compliance.
2023-11-15T21:09:00Z By Adrianne Appel
New York hospitals would be required to have a cybersecurity program that includes regular cyber risk assessments under newly proposed regulations.
2023-11-15T17:00:00Z By Aaron Nicodemus
Firms monitoring employee use of off-channel communications for business purposes face numerous obstacles. How much is enough, in the opinion of regulators? How much is too much, in the eyes of employees? Determinations must be made as regulators crack down.
2024-07-24T15:50:00Z By Aaron Nicodemus
Financial institutions holding Russian sovereign assets that have not reported them to the Treasury Department’s Office of Foreign Assets Control are now required to do so by Aug. 2.
2024-07-23T12:29:00Z By Ruth Prickett
Compliance officers should take note of proposed laws in the U.K. with the newly elected Labor government setting the legislative agenda in the King’s Speech last week, promising consultations on enhanced employee rights and a higher minimum wage.
2024-07-22T15:50:00Z By Aaron Nicodemus
Four federal banking regulators have joined the Treasury Department’s Financial Crimes Enforcement Network in issuing a notice of proposed rulemaking that would require financial institutions to conduct more thorough risk assessments on their anti-money laundering/countering the financing of terrorism programs.
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