RELEVANT EXPERIENCE
Prior to joining Practus, Robert was an Advisory Manager for Deloitte where he advised clients regarding BSA/AML 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, supervision failures, and sales practice violations. He also serves as an outsourced Chief Compliance Officer/AML Compliance Officer for Broker-Dealers and Chief Compliance Officer for Registered Investment Advisers.
Robert’s areas of experience 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
- Served as Chief Compliance Officer and Anti-Money Laundering Compliance Officer for Broker-Dealers.
- Served as Chief Compliance Officer for Registered Investment Advisers.
- Served as an Expert Witness in a FINRA arbitration for the respondents (Registered Investment Adviser and Broker-Dealer) providing expert testimony regarding FINRA rules and the Investment Advisers Act of 1940. Claimant’s claims were denied in their entirety.
- Obtained a decision from FINRA’s Department of Enforcement to not recommend the initiation of formal disciplinary action against a registered representative.
- Convinced a state securities regulator to drop charges against the President/CCO of a Registered Investment Adviser.
- Represented and advised multiple Registered Investment Advisers and Broker-Dealers in regulatory examinations and investigations conducted by the SEC, FINRA, and state securities regulators.
- Convinced the CFP Board not to open an investigation against a Certified Financial Planner.
- Negotiated the successful resolution of a state regulator’s charges against a Registered Investment Adviser.
- Assisted multiple Registered Investment Advisers in registering with the SEC and/or state securities authorities; plus provide advice and assistance in drafting disclosure documents and development of compliance programs.
- Performed for multiple Registered Investment Advisers 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 Broker-Dealers regarding the sales of Leveraged & Inversed ETFs, non-traded REITs, and Variable Annuities.
- Led several teams which investigated and prosecuted Broker-Dealers regarding the sales of unregistered securities.
- Led several investigations and prosecutions of Broker-Dealers 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.
