SEC Rule 15a-6
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20 Minutes
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For all staff
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UK
Non-US firms wishing to engage in securities transactions with US clients must comply with Rule 15a-6, which provides limited exemptions from US registration requirements. This 20-minute course addresses the prohibitions on non-US employees doing business in the US, identifies the exemptions Rule 15a-6 provides, and helps staff recognise the boundaries within which contact is permitted.
The exemptions are narrow and depend on the role of a US registered broker-dealer in the chain, which means an unsupervised call or email can breach them. SEC enforcement reaches firms with no US presence. Training the sales and research staff who might contact a US person keeps the exemption intact, since it is lost through ordinary contact rather than deliberate evasion.