Risk Management & Compliance

Regulatory licensing

  • Assist firms in designing and implementing compliance framework for regulatory licensing
  • Develop policies, procedures, and internal controls for trading, risk management, margin, capital, compliance, cyber security, AML/KYC, and other functions

Governance and supervision

  • Review governance frameworks and advise regarding shareholder relations, management duties and responsibilities, and committee structures and charters

Risk management, trading and surveillance, swap data reporting, and capital adequacy assessments

  • Assess the design and implementation of risk management, trading and surveillance, and reporting (SDR, CAT, TRACE) systems to determine whether they meet regulatory requirements
  • Perform reviews of capital frameworks and regulatory capital modeling approaches

Compliance program assessment and exam preparation

  • Assess compliance programs at banks, broker-dealers, swap dealers, security-based swap dealers, futures commission merchants, consumer lenders, mortgage servicers, digital asset trading platforms, fintechs, and other financial firms to identify control weaknesses or gaps
  • Prepare clients for examinations by U.S. banking regulators and the CFPB, CFTC, FINRA, NFA, and SEC

Representative Engagements

  • Served as an independent compliance consultant for a broker-dealer pursuant to an SEC order focusing on controls and procedures regarding the Rules 15c3-1 (Net Capital) and15c3-3 (Customer Protection)
  • Served as an implementation partner for a leading cryptocurrency institutional brokerage on CFTC and NFA registration and end-to-end implementation of a compliance and risk management program spanning trade surveillance, margin, capital reporting, and client onboarding
  • Conducted for a large financial institution with multiple broker-dealers first an independent review and, thereafter, annual reviews to support CEO certification regarding SEC Rule 15c3-5 (Market Access Rule) compliance, including financial, regulatory, and other risk management controls and supervisory procedures
  • Assessed compliance with CFTC regulations covering policies, procedures, and controls for a major swap dealer, focusing on supervision, business conduct standards, clearing and execution, and large trader reporting
  • Analyzed swap data repository reporting for a large global swap dealer, assessing compliance with CFTC Parts 43 and 45 regulations
  • Served as an independent compliance consultant pursuant to FINRA enforcement actions regarding a broker-dealer’s compliance with blue sheets and TRACE reporting
  • Examined and recommended enhancements to proprietary alternative trading systems
  • Advised a corporate issuer on responding to globally coordinated enforcement actions related to the manipulation of commodities and securities markets
  • Engaged in a detailed review, analysis, and assessment of a major hedge fund’s policies, procedures, systems, and controls designed to prevent the misuse of material non-public information by its employees and to prevent the occurrence of insider trading at the Firm
  • Assisted a large non-bank swap dealer in preparing and filing an NFA capital (market risk) model approval application
  • Analyzed risks and controls related to business processes at a major consumer lender to ensure compliance with CFPB regulations and identified deficiencies
  • Developed processes at a large banking group to stand up a Customer Identification Program and “Know Your Customer” programs to comply with FinCEN requirements
  • Consulted with public companies, clearinghouses, and exchanges regarding corporate governance
  • Advised a large U.S. fintech company on compliance considerations regarding new product offerings and business expansions in Hong Kong and Singapore
  • Developed policies and procedures, trained staff, conducted internal reviews, and managed annual employee certification on Foreign Corrupt Practices Act (FCPA) requirements
  • Assisted with compliance reviews, annual compliance and risk assessments, and Form ADV filings for SEC-registered investment advisors of foreign investment managers
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