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ARTICLE · 09 APRIL 2024

Enforcement Roundup - Regulators Remain Focused On All Aspects Of Recordkeeping

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What does the fining of a major Wall Street firm for trade surveillance failures, the holding to personal account of the CEO of a UK bank, the impact of cyber security incidents at a pair of broker dealers...

United StatesTechnology
Susannah Hammond
Susannah Hammond
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What does the fining of a major Wall Street firm for trade surveillance failures, the holding to personal account of the CEO of a UK bank, the impact of cyber security incidents at a pair of broker dealers and another two firms being held accountable for off-channel communications all have in common? They all represent failures of one or more aspects of upstream recordkeeping with the consequent downstream inability to meet compliance obligations.

Recordkeeping is a core competency for financial services firms. It encompasses a firm knowing what data or records it has, why it has them and where they are. It also covers keeping those records secure and unaltered. Without a comprehensive and robust approach to recordkeeping and the associated data governance, firms will simply not be able to either fulfill or evidence compliance obligations. Firms are utterly reliant on their records to be able to act on everything from responding to

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