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
This SEC enforcement release is the latest iteration of the agency's sweep regarding compliance with the SEC Marketing Rule. The compliance deadline for the Marketing Rule was November 4, 2022. Each of the firms was found to have violated the Marketing Rule by disseminating advertisements that included untrue or unsubstantiated statements of material fact or testimonials, endorsements, or third-party ratings that lacked required disclosures. The fines ranged from $60,000 to $295,000 which,…
This case stands for the commonsense proposition that an advisory relationship must be actually established before any fiduciary obligation will be created. Presumably, this requires both an intent to enter into a formal legal relationship, and the actual signing of an investment management agreement (or equivalent). Also of note is the Court's finding that a mere increase in fees, will not, standing alone, constitute a breach of obligation. To the contrary, to be successful, a plaintiff…