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Enforcement Developments

Law & Legal Proc.
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This session provides an overview of new developments and trends in Enforcement, including Enforcement priorities. Panelists discuss how a matter finds its way to Enforcement and what happens while in Enforcement.

Panelists highlight noteworthy decisions and settlements that illustrate FINRA priorities and provide a view into the process. Panelists also provide guidance on regulatory and compliance practices.

Lecturer Bios

Terrence Bohan

Terrence Bohan is Vice President of Investigations for the FINRA Enforcement department. In that capacity, he manages Enforcement’s investigators located throughout the various FINRA offices nationwide as they investigate potential securities violations and, when warranted, bring formal disciplinary actions against firms and their associated persons.

Mr. Bohan also oversees the Forensic Investigations and Litigation Support group, which supports FINRA’s use of forensic tools and e-discovery technologies. He joined FINRA in 2018. Before joining FINRA, Mr. Bohan spent more than 23 years with the SEC’s New York Regional Office’s broker-dealer inspection program, primarily as a cause examination manager. In that role, Mr. Bohan identified and developed numerous significant cases involving fraudulent securities offerings, manipulations, Ponzi schemes, unregistered distributions of securities, money laundering and egregious sales practice schemes.

He has worked extensively with law enforcement in the New York area, including the U.S. Attorney’s Office, FBI, IRS, Postal Inspection Service and Manhattan District Attorney’s Office. Mr. Bohan received his Bachelor of Science in finance from Fordham University.

Christopher Kelly

Christopher Kelly serves as the Regional Chief Counsel for the North Region of FINRA’s Enforcement Department. As Regional Chief Counsel, Mr. Kelly oversees the work of the Enforcement Staff in the Boston, New Jersey, and Philadelphia District Offices. Prior to joining FINRA, Mr. Kelly served as Deputy Chief of the Criminal Division at the U.S. Attorney’s Office for the District of New Jersey. In that role, Mr. Kelly supervised more than 35 Assistant U.S. Attorneys in the Office’s white collar units: Economic Crimes, National Security, Healthcare and Government Fraud, and Cybercrime.

Prior to his promotion to the position of Deputy Chief, Mr. Kelly served as the Chief of the Economic Crimes Unit at the U.S. Attorney’s Office, where he oversaw the Office’s prosecution of complex economic crimes, including crimes involving insider trading, securities fraud, tax evasion, bank fraud, corporate fraud and embezzlement. Mr. Kelly also served as the lead prosecutor on several complex matters, including U.S. v. Tiger Asia, one of the first ever criminal prosecutions of a hedge fund. Mr. Kelly graduated from Duke University and Harvard Law School. Prior to joining the U.S. Attorney’s Office, he was an associate at the law firm Dechert LLP. Mr. Kelly also clerked for the Honorable Joseph E. Irenas, U.S. District Court Judge for the District of New Jersey.

Lara Thyagarajan, Esq.

Lara Thyagarajan is FINRA’s Senior Vice President, Head of Market Regulation Enforcement and Litigation. Prior to serving in her current role, Ms. Thyagarajan was the Senior Vice President and Counsel to the Head of Enforcement and prior to that was the Chief Counsel for the New York Region in FINRA’s Department of Enforcement.

She joined FINRA's predecessor, NASD, in 2006. Before joining FINRA, Ms. Thyagarajan was a partner in the securities enforcement defense practice of a Boston law firm where she focused on the defense of investment advisors and broker-dealers primarily in SEC investigations and hearings. Ms. Thyagarajan graduated from Boston College Law School and received her B.A. from Boston University.

Kayte Toczylowski

Kayte Toczylowski is Vice President of Member Relations and Education for FINRA. In leading the Member Relations and Education Department, Ms. Toczylowski’s responsibilities include maintaining and enhancing open and effective dialog with FINRA member firms.

Ms. Toczylowski also oversees FINRA’s Member Education area, which includes FINRA conferences and other member firm educational offerings such as the FINRA Institute at Georgetown for the Certified Regulatory and Compliance Professional (CRCP)® designation. Ms. Toczylowski has been with FINRA since 2011 and spent nine years in Member Supervision’s examination program. Most recently,

Ms. Toczylowski was an Examination Director located in the Philadelphia, PA office, where she led geographically dispersed exam teams responsible for planning and executing Member Supervision’s examination program relative to a subset of firms engaged primarily in Capital Markets & Investment Banking Services. She entered the securities industry in 2003 in the compliance department of Janney Montgomery Scott, a regional broker-dealer headquartered in Philadelphia.

The majority of her eight-year career at Janney was spent as a compliance examiner for the firm’s branch network. Ms. Toczylowski has a Bachelor of Arts degree in English from Villanova.

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