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Whistleblower Policies
  • Sullivan & Worcester LLP
  • USA
  • January 25 2019

On January 7, 2019, the New York State Department of Financial Services (the "DFS") issued new guidance on whistleblowing programs ("WP") to all


Customer Due Diligence and FinCEN’s Frequently Asked Questions
  • Sullivan & Worcester LLP
  • USA
  • May 9 2018

As you are aware, FinCEN’s Customer Due Diligence rules are effective in two days. In a nutshell, these rules require banks to obtain and verify the


How Many Times Does the SEC Have to Repeat Itself Before the World Listens?
  • Sullivan & Worcester LLP
  • USA
  • December 15 2017

Remember in July of this year when the Securities and Exchange Commission (SEC) said in its Decentralized Autonomous Organization (DAO) Report that...


A Shot Across the Bowand a Welcome One
  • Sullivan & Worcester LLP
  • USA
  • July 27 2017

In the wild west of token sales, that some refer to as "initial token offerings," on July 25, the SEC finally jumped into the fray and said


Asset Managers, Are You Ready for Your Exam? Steps You Should Take Now
  • Sullivan & Worcester LLP
  • USA
  • March 17 2017

Last week we told you about the five biggest pet peeves of the SEC’s Office of Compliance Inspections and Examinations (OCIE) when examining


The Top Five "Gotcha" Deficiencies Plaguing Asset Managers and How to Avoid Them
  • Sullivan & Worcester LLP
  • USA
  • March 1 2017

Let’s start with this caveat: as we all know, under the still-new Trump Administration, priorities may and are likely to change. Now that we got that


Financial Regulatory Reform It's Coming, Unless it Doesn't
  • Sullivan & Worcester LLP
  • USA
  • November 21 2016

If you're like me, you are constantly receiving alerts from consultants, law firms, policy shops and others, all predicting how the Trump


Joel S. Telpner
  • Sullivan & Worcester LLP