End Of Year Compliance Requirements For Broker Dealers

Posted on October 17th, 2014 by Mitch Avnet


End of Year Compliance Requirements For Broker Dealers

As the end of 2014 quickly approaches, this Compliance Bulletin serves as a notice and reminder to Broker Dealers regarding year-end responsibilities that must be executed in accordance with FINRA / SEC regulatory requirements. Reconciling your current “state of compliance” is the most effective way to ascertain your program’s status and ensure your firm continues to meet its ongoing regulatory requirements.

Compliance Bulletin 04-14 includes information on:

compliance bulletin

  • FINRA 3012 / 3130 Testing and Certification – Identifying Hot Topic Issues
  • SEC Rule 17a-5 – Annual Compliance Report
  • Independent Anti-Money Laundering (“AML”) Test / Review
  • Written Supervisory Procedures (“WSPs”) Review
  • Continuing Education and Branch Office Reviews
  • Annual Compliance Meeting, Registrations and Renewals

Fill out the form below to download your complimentary Compliance Bulletin titled You Better Check Yourself- Before You Wreck Yourself.

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Shift Happens | Corporate Culture For Compliance Hiring

Posted on September 11th, 2014 by Kristy Wright Skeehan


Alternative asset managers are starting to take regulatory compliance more seriously, with a spike in hiring of compliance professionals this year. The shift comes even amid evidence that some managers, especially smaller ones, seem to take a dismissive view toward compliance – an attitude that experts say could cost them dearly in the long run.

Managers are responding by creating and filling new compliance positions, and there’s a lot of activity, says Jason Wachtel, founder and managing partner at JW Michaels & Co., a recruiting firm that specializes in compliance and legal hires. “Across the board, everybody’s hiring,” he says. “I’ve never seen it this busy before.” He expects that pace to continue for the rest of this year and into 2015 and beyond, he adds. 

Read more on “Shift Happens | Corporate Culture For Compliance Hiring” »


JW Michaels ranked #792 on the 2014 Inc. 5000 list

Posted on August 21st, 2014 by Kristy Wright Skeehan

Ince. 5000On Wednesday, August 20, Inc. magazine released it’s annual list of the top fastest growing privately held companies. JW Michaels was ranked #792 on the list of 5,000. Inc. has been ranking private companies for 33 years, so this is quite an honor!

We would like to thank all our clients and candidates for making this achievement possible. We’re on track for even greater growth in the near future, and we look forward to making the Inc.‘s top 500 next year!

Check out the full list here: http://www.inc.com/inc5000/index.html

Read more on “JW Michaels ranked #792 on the 2014 Inc. 5000 list” »


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Co-founder Justin Mandel discusses the hiring of OFAC staff

Posted on August 13th, 2014 by Kristy Wright Skeehan

Justin MandelIn a recent Bloomberg article, JW Michaels co-founder Justin Mandel discusses the need for compliance executives to have an understanding of the intricacies of US sanctions laws. The need for such expertise has led banks and asset managers to look for compliance staff at the Treasury Department’s Office of Foreign Assets Control.

Mandel explains, “Having someone who has come directly from those regulatory bodies or otherwise understands the evolving rules and regulations gives firms a significant advantage. OFAC is one of those areas where it’s relevant.”

Read more on “Co-founder Justin Mandel discusses the hiring of OFAC staff” »


The Hedge Fund Law Report: Jason Wachtel provides insight into hedge fund compensation

Posted on July 24th, 2014 by Kristy Wright Skeehan

In a recent interview with The Hedge Fund Law Report, JW Michaels’ Managing Partner Jason Wachtel discussed the compensation levels of hedge fund GCs and CCOs. He explained how compensation is usually determined, saying:

“The range in compensation is really determined by a few things: assets under management, performance of the fund and the personnel and the strategy of the fund.  If it’s a vanilla long/short equity fund with $1 billion under management, the performance is average, and the general counsel has only been with the fund for about a year, the compensation would be expected to be closer to the lower end of the spectrum.  When it comes to compensation, you want to look at when the person joined the firm, how the fund has performed and grown since that time and the person’s role within the firm. The more responsibilities and authority a person has within the firm, the more you can expect to layer on to the compensation.”

Read more on “The Hedge Fund Law Report: Jason Wachtel provides insight into hedge fund compensation” »


Wall Street Journal: Hire Compliance Now, or Get Fined Later

Posted on July 11th, 2014 by Jason Wachtel

This article originally published in the Wall Street Journal : The Morning Risk Report

compliance quoteThe boom in the hiring of chief compliance officers and mid-level compliance staff is driven by not only an explosion of rules and regulations but by the fear of becoming the next poster child for wrongdoing, says an executive at a national recruitment firm specializing in hiring of compliance officers and legal personnel.

Rules and regulations such as the Volcker Rule and Dodd-Frank Act, which marks its fourth anniversary later this month, have served as a wake-up call to banks, hedge funds and private equity firms that it’s better to spend money on compliance than to get fined millions or billions of dollars, then suffer additional losses as investors pull money, said Jason Wachtel, managing partner of recruitment firm JW Michaels & Co. His firm has increased its staff from two people to 50 since the financial crisis hit in 2008. “If you’re a hedge fund or private equity firm with more than $500 million under management, you’re looking for really talented people for compliance and legal,” he said. “Most firms have hired their chief compliance officer in the last two years and now are further building out their compliance infrastructure. They need more hands on deck.”

Read more on “Wall Street Journal: Hire Compliance Now, or Get Fined Later” »


RCA Extends Special Recognition to Jason Wachtel, Managing Partner of JW Michaels & Co.

Posted on July 8th, 2014 by Kristy Wright Skeehan

rcaThe Regulatory Compliance Association (RCA), and its 78,000 asset management executive members have commended JW Michaels for its endowment of RCA’s myUniversity and PracticEdge Curricula.

Specifically, the RCA extended a special accommodation to managing partner Jason Wachtel as the Senior Fellow from Practice for “Compensation Trends in Alternative Asset Management,” an RCA PracticEdge session Jason led in February. The session also included presentations and discussion by Jason Blain, head of JW Michaels’s Finance and Accounting practice, and Fred Davis, head of the Risk and Quant practice

CLICK HERE for more information on JW Michaels & Co.’s endowment and The Regulatory Compliance Association myUniversity and PracticEdge Curricula.

Read more on “RCA Extends Special Recognition to Jason Wachtel, Managing Partner of JW Michaels & Co.” »


BNP Paribas nearing settlement over sanctions violations

Posted on June 25th, 2014 by Kristy Wright Skeehan

French bank BNP Paribas SAThe compliance world is busy talking about the recent news that French bank BNP Paribas SA will likely pay a record fine of over $8 billion as part of a settlement with the Justice Department over violations of sanctions related to Sudan.

Bloomberg reports that BNP Paribas conducted billions of dollars of illegal transactions on behalf of companies and government agencies in Sudan over five years.

According to Reuters, authorities are investigating whether the bank stripped out identifying information from wire transfers so the transfers could pass through the U.S. financial system without raising red flags.

In addition to paying the fine, BNP Paribas will likely plead guilty to a criminal charge of conspiring to violate the International Emergency Economic Powers Act and agree to a temporary prohibition on conducting transactions in U.S. dollars.

Sources: Bloomberg Businessweek; Reuters



Posted on June 19th, 2014 by Mitch Avnet

Summary:  Dodd-Frank Trade Reconstruction Expert Panel
Dodd Frank Think Tank

On June 5th, 2014, Bloomberg Vault and Compliance Risk Concepts (“CRC”) hosted a special roundtable at Bloomberg’s New York headquarters specific to the Commodity Futures Trade Commission’s (“CFTC”) Trade Reconstruction Requirements for swap entities.   The event was attended by senior compliance executives and financial services firms representing nearly 10 percent of institutional investment firms impacted by these regulatory requirements.

Read more on “CFTC SWAP TRADE RECONSTRUCTION Think Tank Summary” »


Thriving CRC Partnership Results In Plans for Expansion For Four Points

Posted on June 18th, 2014 by Kristy Wright Skeehan

NEW YORK, NY, June 18, 2014 /24-7PressRelease/ – Four Points Capital Partners LLC (“Four Points”), a New York based independent brokerage has found a way to rise above, in their strategic partnership with Compliance Risk Concepts (“CRC”). Read more on “Thriving CRC Partnership Results In Plans for Expansion For Four Points” »