Compliance & Ethics

The CFTC approved a final rule establishing a 30 percent presumptive award for whistleblower awards of USD $5 Million or less, subject to Commission discretion and its analysis of relevant regulatory factors. Modeled on SEC Rule 21F-6(c), the rule aligns the two agencies' whistleblower frameworks. Compliance teams should reassess internal reporting programs, because the clearer and more predictable award structure may increase incentives for employees to report externally.

The Securities and Exchange Commission has more than 34,000 registered entities within the reach of its examination program. For fiscal year 2027, the agency has identified private credit, investment adviser conflicts, cybersecurity and emerging technologies among the areas where it intends to concentrate its attention.

From April 2022 to November 2023, according to federal prosecutors, a TD Bank employee in Florida opened fraudulent accounts and issued hundreds of debit cards to co-conspirators. When the bank restricted some of the cards over possible fraud, he unblocked them. About $4.8 million left the United States for Colombia through the accounts and cards. Eighty-six of the accounts used the same commercial address in Miami and carried more than $3 million of that total. He took more than $8,000 in bribes, paid in cash and through a peer-to-peer payment app.

The Norway Financial Supervisory Authority (Finanstilsynet) has posted a warning about Legacy Trading Global, based on a notice originally issued by the UK Financial Conduct Authority (FCA). The source material is limited, but it signals a probable unauthorized or fraudulent investment solicitation that compliance teams should add to their screening and client-protection controls.

The FCA will pause document allocation, responses, and listing hearings from December 21, 2026 to January 4, 2027 inclusive, with normal activity resuming January 5, 2027. Those days will not count toward standard turnaround times, and revised timetables and early cutoffs apply to Final Terms and Outstanding Conditions. Compliance and deal teams should plan transaction timetables now to avoid missed windows and stale financial information.

The Norway Financial Supervisory Authority has published a warning that references a Central Bank of Ireland notice on "Carrowmore Financial Services (CLONE)," an unauthorized firm that appears to be impersonating a legitimate entity. Compliance teams should treat the name as a fraud and impersonation red flag and update screening and customer-warning controls. The source material is brief, so teams should consult the original Irish notice for specifics.

The BfDI has issued recommendations, based on a survey of 1,500 insured persons, urging the German Federal Government to strengthen transparency and granular user controls in the electronic patient file (ePA). From the end of October 2026, pseudonymized medication list data can be extracted for research unless insured persons object. Compliance teams at organizations handling German health data should treat this as a signal of regulatory expectations on consent, control, and transparency.