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Today I’d like to bring to attention some of the new requirements in the Dodd-Frank Wall Street Reform and Consumer Protection Act. An article by Courthouse News describes how new rules enacted by the Commodity Futures Trading Commission under Title VII of the Dodd-Frank Act require commodities swaps service providers to implement new record-keeping and firewall policies. Those affected include futures commission merchants, introducing brokers, dealers and other major participants in commodities swaps.
Swap service providers must appoint a chief compliance officer to maintain firewalls between their clearing personnel and trading business personnel as well as between research personnel and non-research personnel,” in order to prevent unfair internal sharing of information. Compliance with these regulations as well as the new written and oral communication storage requirements will be new for these entities, and Guidepost Solutions has the expertise to assist companies with these types of compliance issues to avoid future legal problems.
Kenneth Citarella is senior managing director for the Investigations and Cyber Forensics practice at Guidepost Solutions LLC. He has more than 30 years of experience investigating and prosecuting white collar crime and computer crime.