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      Page 36 - 期貨和衍生品行業(yè)監(jiān)管動態(tài)(2024年8月刊)
      P. 36

      期貨和衍生品行業(yè)監(jiān)管動態(tài)
      
      
      
      
                         use of unapproved communications methods. How? Truist made the decision to
      
                         self-report to the Division of Enforcement it had serious recordkeeping and
      
                         supervisory failures. It is the only registrant to do so,” said Director of Enforcement
      
                         Ian McGinley. “Truist’s decision to self-report, cooperate, remediate, and be held
      
                         accountable allowed it to benefit in the form of a substantially reduced penalty. At the
      
                         same time, the CFTC’s message remains clear—recordkeeping and supervision
      
                         requirements are fundamental, and registrants that fail to comply with these core
      
                         obligations do so at their own peril.”
      
      
                              Case Background
      
      
                              From December 2019 through the present, Truist’s policies and procedures
      
                         broadly prohibited employees from using unapproved communication methods, such
      
                         as personal text messages and social applications, to engage in business-related
      
                         communications about the firm’s swap dealer. Truist required regular attestations from
      
                         swap dealer employees that they were not using personal text messages and social
      
                         applications to engage in business-related communications.
      
      
                              Messages sent through Truist-approved communications methods were
      
      
                         monitored, subject to review, and when appropriate, archived. By contrast, messages
                         sent using unapproved communication methods, including personal text messages,
      
      
                         were generally not monitored, subject to review, or archived.
      
      
                              As a result of Truist’s failure to ensure that employees—including supervisors
      
                         and senior-level employees—complied with the firm’s communications policies and
      
                         procedures, Truist failed to maintain many business-related communications,
      
                         including communications in connection with its commodities and swaps business,
      
                         and thus failed to diligently supervise its business as a CFTC registrant.
      
      
                              After reviewing public CFTC orders entered with other CFTC registrants for
      
                         similar conduct, Truist undertook its own internal survey of senior employees,
      
                         identified potential violations, and promptly self-reported those facts to the CFTC.
      
      
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