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Managing the Risks of Master/Sub-Account Relationships

By Alma Angotti , Jay Perlman , Ellen Zimiles

The SEC recently issued a National Exam Risk Alert to registered broker-dealers detailing many of the significant compliance risks that can arise as a result of the master/sub-account trading model. In addition, both FINRA and the SEC have announced that master/sub-account relationships and the regulatory issues arising out of direct market access are examination priorities. In this white paper, Ellen Zimiles, Alma Angotti and Jay Perlman outline several steps that broker-dealers in securities that have master/sub-account trading structures can take to ensure compliance with all applicable laws and regulations and address the risk presented by their customers.  

Experts

Alma Angotti

Alma Angotti is a Director in the Global Investigations & Compliance practice with 25 years regulatory experience. She is a widely recognized anti-money laundering expert.

Jay Perlman

Jay is a director with the Global Investigations & Compliance segment, and has 20 years of legal, regulatory compliance and investigative experience in the financial services and corporate sectors.

Ellen Zimiles

Managing Director, Head of Global Investigations & Compliance segment, she is a leading authority on anti-money laundering, regulatory and corporate compliance, fraud control, and public corruption matters.

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