Escalation Upon Discovery of Prohibited Activity
Chapters in this video
- 0:00 The three-step supervisory framework: recognize, investigate, escalate
- 2:39 Internal escalation ladder: CCO, legal, senior management, board
- 3:21 External triggers: Form U4, SAR filings, and the 30-day rule
- 4:32 Manipulation discoveries: freeze trading, litigation hold, preserve records
- 6:07 Supervisory-system umbrella: failure to detect vs failure to act vs failure to escalate
- 7:42 Rapid-fire exam recap
What this video covers
- The three-step supervisory framework: recognize, investigate, escalate, and why waiting for definitive proof before acting is itself a failure
- The internal escalation ladder from trading desk supervisor to Chief Compliance Officer (CCO), legal, senior management, and board/audit committee
- When a written customer complaint alleging theft or misappropriation triggers external regulatory event reporting regardless of dollar amount
- Form U4 amendment obligations via Web Central Registration Depository (Web CRD) and Suspicious Activity Report (SAR) filings to the Financial Crimes Enforcement Network (FinCEN)
- The 30-day regulatory-event reporting deadline and when quarterly reporting applies
- Why manipulation or front-running discoveries require freezing trading immediately and preserving records under a litigation hold the moment suspicion arises
- Why a supervisor's failure to escalate is a separate supervisory-system failure, distinct from the underlying trading violation
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