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FINANCIAL & CAPITAL MARKETS

Whistleblower program compliance

Whistleblower program compliance in financial and capital markets is under active pressure from multiple directions at once. The U.S. Securities and Exchange Commission has paid out over $1 billion in whistleblower awards under its Rule 21F program, and firms with deficient anti-retaliation policies have drawn enforcement actions, not just guidance letters. The Financial Industry Regulatory Authority and the Consumer Financial Protection Bureau have each added supervisory teeth to internal reporting channel requirements, giving compliance officers three distinct frameworks to reconcile across overlapping product lines.

Watch

  • SEC Rule 21F award volume: trends in award size and covered conduct categories
  • Anti-retaliation enforcement actions targeting confidentiality agreements in employment contracts
  • CFPB supervisory expectations for internal whistleblower intake channels at nonbank lenders
  • FINRA Rule 3110 exam focus on escalation procedures for reportable misconduct
  • Proposed EU Whistleblower Directive implementation gaps affecting U.S. firms with EU operations

Recent material activity in Financial & Capital Markets

  • Sep 4, 2026MATERIAL

    Federal Reserve terminates cease-and-desist order against United Texas Bank and written agreement with Quontic entities

    The Federal Reserve Board terminated two enforcement actions effective September 2, 2026. The terminations close a cease-and-desist order issued to United Texas Bank in August 2024 and a written agreement with Quontic Ba…

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  • Sep 4, 2026MATERIAL

    Cboe Exchange files immediately effective rule change to implement an Order Entry Protocol Migration Program

    On September 4, 2026, the SEC granted immediate effectiveness to a Cboe Exchange rule filing that amends its fee schedule to establish an Order Entry Protocol Migration Program. The filing signals a structured transition…

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  • Sep 4, 2026MATERIAL

    Nasdaq files immediately effective rule change amending disciplinary code Rule 9558

    On September 4, 2026, the SEC published Nasdaq's notice of filing for an immediately effective amendment to Rule 9558 of Nasdaq's Disciplinary Code. The amendment takes effect without a standard comment period under the …

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  • Sep 4, 2026MATERIAL

    ESMA-SEBI MoU reopens the path for Indian CCP recognition under EMIR after a two-year suspension

    ESMA signed a Memorandum of Understanding with the Securities and Exchange Board of India on September 4, 2026, covering supervisory cooperation and information exchange for Indian central counterparties. This agreement …

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  • Sep 4, 2026MATERIAL

    SFC issues supervisory circular to licensed corporations, virtual asset service providers, and associated entities on brokers forum conduct

    On September 4, 2026, the Securities and Futures Commission issued a circular to licensed corporations, SFC-licensed virtual asset service providers, and their associated entities, setting out conduct and supervisory exp…

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  • Sep 4, 2026MATERIAL

    ASIC review finds cash settlements used in 63% of home insurance claims, flags systemic consumer harm risks

    ASIC's August 31, 2026 review finds systemic failures in cash settlement practices across approximately 65% of the Australian home insurance market. The review identifies deficiencies in settlement adequacy, support for …

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  • Sep 4, 2026MATERIAL

    Federal Court orders CashnGo to pay $3.5 million for unfair contract terms across 201,000 small-amount credit contracts

    On 2 September 2026, the Federal Court imposed a $3.5 million penalty against Venture 5 Group Pty Ltd, trading as CashnGo, in proceedings brought by ASIC. The judgment declares multiple contract terms void, mandates opt-…

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  • Sep 4, 2026MATERIAL

    ASIC secures insider trading conviction against former Beacon Minerals project manager following five-year prosecution

    The Supreme Court of Western Australia sentenced Alexander John McCulloch on 25 August 2026 to 12 months' imprisonment for one count of insider trading under the Corporations Act 2001. McCulloch, a former project manager…

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  • Sep 4, 2026MATERIAL

    South Korea's FSC expands network separation rule exemption to nonbank firms and electronic financial service providers for frontier AI cybersecurity testing

    The Financial Services Commission announced on September 3, 2026 the second phase of its network separation rule easing, expanding eligibility beyond banks to nonbank financial companies and electronic financial service …

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  • Sep 4, 2026MATERIAL

    SEBI announces review of derivative contract settlement price methodology following Centralized Accounting System rollout

    SEBI's Press Release 53/2026, issued September 3, 2026, announces a review of settlement price methodology for derivative contracts. The review is tied to the Centralized Accounting System rollout, signaling a potential …

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