Robert Moreiro

RELEVANT EXPERIENCE

Prior to joining Practus, Robert was an Advisory Manager for Deloitte where he advised clients regarding BSA/AML and OFAC compliance issues. Robert also spent over ten years at FINRA where he served as Senior Counsel in the Department of Enforcement. While at FINRA, Robert lead many complex investigations and prosecutions involving, among other things, securities fraud, market manipulation, AML and supervision failures, and sales practice violations. He also serves as an outsourced Chief Compliance Officer/AML Compliance Officer for a FinTech broker-dealer.

Robert’s areas of expertise include:

Anti-Money Laundering, Broker-Dealer Formation, Regulation and Compliance, Investment Adviser Formation, Regulation and Compliance , Outsourced Chief Compliance Officer and Anti-Money Laundering Officer Services, Ongoing Compliance Services for Investment Advisers and Broker-Dealers, Securities Enforcement and Regulation, and FINRA

REPRESENTATIVE MATTERS

• Convinced a state securities regulator to drop charges against the President/CCO of an investment advisory firm.
• Represented and advised multiple investment advisory firms in regulatory examinations conducted by the SEC or state securities regulators.
• Convinced the CFP Board not to open an investigation against an investment adviser.
• Negotiated the successful resolution of a state regulators charges against an investment advisory firm.
• Assist multiple investment advisory firms in registering with the SEC and/or state securities authorities and coordinating with regulatory authorities during the application process; plus provide advice and assistance in the drafting disclosure documents and development of compliance programs.
• Performed for multiple investment advisory firms their required annual review of their Compliance Program as required by Rule 206(4)-7 of the Investment Advisers Act of 1940.
• Led several teams which investigated and prosecuted members firms regarding the sales of Leveraged & Inversed ETFs, non-traded REITs, and Variable Annuities.
• Led several teams which investigated and prosecuted member firms regarding the sales of unregistered securities.
• Led several investigations and prosecutions of member firms regarding their AML Compliance Programs.
• Litigated a disciplinary action against a registered principal and registered representative regarding the sales of unregistered securities.
• Managed multiple independent BSA/AML testing engagements. Led engagement staff in conducting the independent testing of financial institutions’ BSA/AML Compliance Program to ensure compliance with applicable BSA/AML regulatory requirements, regulatory expectations and prevalent industry practices.
• Conducted several AML validations for projects designed as response to regulatory consent orders.Liaised and communicated with Business teams that completed the AML projects to understand actions taken. Ensured projects were within the requirements of the consent orders.