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Books and Records in the Regulatory Spotlight

The end of 2021 saw the SEC fine a large U.S. securities firm $125 million for “widespread” failure to keep adequate records of staff communications on personal mobile devices, messaging apps, and emails. With the SEC indicating that they are currently investigating other firms’ record keeping practices, more enforcement is likely expected in 2022.

And it doesn’t end with electronic communications. The enforcement reflects the Gensler administration’s priority on proper record keeping across the organization. Firms of all sizes should be taking a hard look at their electronic record preservation systems, reporting abilities and related policies and procedures in areas like gifts and entertainment, outside business activities and political contributions as well.

Can your audit trail stand up to regulatory scrutiny?

Join Jane Shahmanesh from Adherence LLC for a discussion of the importance of electronic recordkeeping in compliance including:

  • An analysis of recent regulatory enforcement
  • Proposed amendments to SEC Rules 17a-4 and 18a-6
  • Impact of remote work and the use of non-company devices
  • Practical guidance on what firms need to be doing right now


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Jane Shahmanesh is a Founding Partner and Managing Director at Adherence, LLC, a firm that specializes in regulatory compliance for financial service firms - and its affiliated law firm. Adherence focuses on providing outsourced compliance solutions which can include acting as or supporting the Chief Compliance Officer

Prior to founding Adherence, Jane worked as an in-house legal and compliance lawyer for a Who’s Who of financial institutions – including Lehman Brothers (where she counseled the bankrupt entity’s derivative unwind),  Goldman Sachs & Co. (where she ran a division of their Compliance Department), Credit Suisse (where she was the interim legal manager for CSAM and its hedge fund businesses), Citibank (where she was the General Counsel to the Private Bank), and Deutsche Asset Management (legacy Bankers Trust)(where she supervised the legal and compliance department).

She was also a Partner at McGuireWoods, LLP, one of the nation’s largest law firms. Jane currently teaches regulatory compliance at Pace Law School. She has a BA from Barnard College and a JD from American University.

Jane Shahmanesh
Managing Director, Adherence LLC