Partner
Norton Rose Fulbright US LLP
Jeff Ziesman is a Partner based in St. Louis. He assists financial institutions with regulatory matters brought by the US Securities and Exchange Commission (SEC), the Financial Crimes Enforcement Network (FinCEN), Financial Industry Regulatory Authority (FINRA) and state securities regulators. His clients range from large financial organizations with a global reach to mid-sized regional businesses.
Jeff provides clients with preventive guidance, reviewing overall compliance programs, performing gap analysis and risk assessments and assisting with analyses of historical transactions. He has brought many groundbreaking enforcement cases in the AML space, including several FINRA press release matters.
Recent Articles & Comments
Outside business activities ("OBA") have been a problematic aspect of broker-dealer supervision for over 25 years. Many representatives are entrepreneurial by nature and are motivated to explore "business opportunities." When a broker-dealer receives a notice of an OBA, it is required to evaluate whether to approve it, and also assess whether the outside activity is, in fact, a private securities transaction.
According to the facts in this AWC, the representative disclosed an OBA that…
Firms were required to provide customers with a Customer Relationship Summary ("Form CRS") beginning June 30, 2020. Implicit in this requirement was that the Form CRS, which identifies basic information about a Firm's services and background, was accurate. Among the items included on a Form CRS are a Firm's and its representatives' disciplinary history.
Here, the Firm did not disclose for several years on its Form CRS that one of its associated persons had a disciplinary history…
The Financial Action Task Force list of jurisdictions found to have strategic AML/CFT deficiencies is separate from those on the US Department of Treasury's OFAC Lists. Financial Institutions doing business in connection with these countries should have enhanced policies and procedures to account for such heightened risk.
FinCEN, FINRA and the SEC (and other AML regulators) expect US financial institutions to be familiar with these jurisdictions, and the institutions' risk-based…
This matter involved a Firm with 18 registered representatives, and whose business (since 2020) was primarily the sale of private placement securities offerings to customers including retail investors. FINRA charged the Firm with "willful" violations of Regulation BI, with the crux of the matter being the recommendation to investors to purchase $140 million in 13 Regulation D private placement offerings. FINRA determined that the Firm's due diligence for some of the private placement…