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Government concern about the state of the energy markets has led to new rules, and to action by regulators targeted at the energy and commodity sector.
The SEC’s order alleged that Moog violated the recordkeeping and internal accounting controls provisions of the FCPA.
He joined the SEC in 2021 and has overseen cases ranging from Regulation Best Interest to greenwashing charges.
The firm was accused by the SEC of failing to disclose potential conflicts of interest resulting from the fees it received from outside investors.
As a registered futures commission merchant CHS was required to make and keep these audio recordings for not less than one year.
The dissenters questioned whether the definition of “business records” has been stretched beyond usefulness.
The fines totalled over $115m – with one firm dodging the bullet but still finding sympathy from two dissenting commissioners.
The firm received no penalty because of its proactive approach, swift remediation and substantial cooperation efforts with the SEC’s investigation of a third party.