: The European Banking Authority (EBA) today published clear guidance for banks on how to manage enhanced reporting requirements for operational risk, following the postponement of the first reference date under the amended Implementing Technical Standards (ITS). This move comes after the European Commission adopted Regulation (EU) 2025/2475, which delays the application of new operational risk reporting obligations to the end of June
: The Federal Trade Commission is taking action against Illusory Systems Inc. for failing to implement adequate data security measures, leading to a major security breach in which hackers stole $186 million from consumers. Under a proposed order settling the FTC’s allegations, Utah-based Illusory, which does business as Nomad, will be required to implement an information security program to address numerous alleged security failures and to return recovered money to affected consumers. “The FTC Act requires companies to take reasonable security measures,” said Christopher Mufarrige, Director of the FTC’s Bureau of Consumer Protection. “It’s important that companies live up to their security promises to consumers.” In its complaint , the FTC alleged that Nomad prominently touted its security in its advertising, claiming that it offered “security-first” services. The FTC, however, alleged that the company failed to live up to these promises by failing to: use secure coding practices; implement processes for recei[...]
: Brussels, 06 May - During its latest plenary, the European Data Protection Board (EDPB) adopted an opinion on the European Commission’s draft adequacy decision under the GDPR concerning the European Patent Organisation (EPO) . In addition, the Board adopted an opinion on the European Commission’s proposal to extend the validity of the UK adequacy decisions under the GDPR and the Law Enforcement Directive (LED) . Finally, the EDPB agreed to grant the status of observer to the Personal Data Protection Agency of Bosnia and Herzegovina. Adequate protection of personal data by the EPO At the European Commission’s request, the Board adopted an opinion on the Commission’s draft adequacy decision regarding the European Patent Organisation (EPO). Once formally adopted by the Commission, this will be the first adequacy decision concerning an international organisation and not a country or a region. An adequacy decision is a key-mechanism in EU data protection legislation which allows the European Commission to deter[...]
: Brussels, 09 October - The European Data Protection Board (EDPB) and the European Commission endorsed joint guidelines on the interplay between the Digital Markets Act (DMA) and the General Data Protection Regulation (GDPR) . These are the first joint guidelines by the Board and the European Commission. In line with its 2024-2027 Strategy and the recent Helsinki Statement’s objectives to make GDPR compliance easier and strengthen consistency, the EDPB has cooperated with the European Commission, each within their respective mandates, to facilitate the coherent application of the DMA*and GDPR and to increase legal certainty for gatekeepers, business users, beneficiaries and individuals. EDPB Chair Anu Talus said: “These joint guidelines are the result of a fruitful cooperation between the EDPB and the European Commission. This is the first time that the EDPB and the European Commission prepare guidelines jointly. This approach maximises usefulness of the guidance by simplifying compliance for businesses and[...]
: FleetCor and its CEO will pay $100 million to settle a Federal Trade Commission administrative action alleging that the company charged its customers, who overwhelmingly are small businesses, undisclosed fees in connection with their use of fuel cards that FleetCor falsely promised businesses would save them money. In a complaint first filed in federal court in 2019 , the FTC alleged that FleetCor Technologies Inc., now known as Corpay Inc., and its CEO Ronald Clarke imposed a broad array of unauthorized fees that its customers never knew about and did not agree to pay, totaling hundreds of millions of dollars and harming tens of thousands of customers. In addition, FleetCor charged late fees to customers who had either paid on time or were prevented by FleetCor from paying on time. FleetCor also misrepresented the gas savings, fraud-control features, and fees associated with its fuel cards. “FleetCor deceived its small business customers by promising fuel savings that never materialized, while unfairly cha[...]
: The European Agency for Safety and Health at Work (EU-OSHA) today inaugurated its new offices in the BAT (B Accelerator Tower), in a ceremony presided over by the European Commission Executive Vice-President for Social Rights and Skills, Quality Jobs and Preparedness, Roxana Mînzatu . Also taking part in the event were William Cockburn , Executive Director of EU-OSHA; Mikel Torres , Deputy First Minister and Minister of Economy, Labour and Employment of the Basque Government; Ainara Basurko , Provincial Councillor for Economic Promotion and First Deputy General; and Amaia Arregi , First Deputy Mayor and Counsellor for Security at the Bilbao City Council. During the inauguration, European Commission Executive Vice-President Roxana Mînzatu highlighted that EU-OSHA’s new headquarters in the BAT marks the beginning of a new chapter for the Agency, which has been based in Bilbao since 1996 and has become Europe’s reference point for occupational safety and health. She noted that the building symbolises values suc[...]
: Brussels, 3 December - As part of its December’s plenary meeting, the European Data Protection Board (EDPB) held yesterday an online meeting with Commissioners and representatives of Data Protection Authorities (DPAs) from the countries and the organisation with an EU adequacy decision. This meeting marked the second of its kind, following the first gathering in October 2024 . An adequacy decision is a key-mechanism in EU data protection legislation which allows free flow of personal data from Europe to third countries or an international organisation offering an adequate level of data protection.* To date, the following countries and organisation benefit from this: Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Republic of Korea, Switzerland, United Kingdom, Uruguay, United States, and the European Patent Organisation . Data Protection Authorities from those countries and the European Patent Organisation are key partners for the EDPB, playing a key ro[...]
: The Federal Trade Commission finalized an order with Publishing.com LLC and its two principals, settling allegations that they misled consumers about how much money consumers were likely to earn using their self-publishing products. Under the order finalized by the Commission, Publishing.com and its principals, CEO Christian Mikkelsen and Chief Product Officer Rasmus Mikkelsen, will pay $1.5 million and be required to substantiate earnings claims in the future. In a complaint first announced in April 2026, the FTC alleged that Publishing.com claimed its programs and services would help consumers earn substantial income publishing e-books and audiobooks online. The FTC further alleged that Christian and Rasmus Mikkelsen claimed that they personally used this system to obtain significant wealth through online self-publishing. The FTC alleged, however, that most consumers who bought Publishing.com’s products and services never made the income the company promised in its advertising. Consumers who sought refunds[...]
: The Federal Trade Commission finalized orders requiring Cox Media Group (CMG) and two other firms to pay a total of $930,000 to settle allegations they deceived customers by falsely claiming to offer an AI-powered service that could target localized ads based on conversations captured from consumers’ smart devices and that consumers had opted into such targeting. In three separate complaints first announced in May , the FTC alleged that Georgia-based media and marketing company CMG Media Corporation, which does business as Cox Media Group , and two marketing firms it worked with, New Hampshire-based MindSift LLC and Wisconsin-based 1010 Digital Works LLC , deceived customers by claiming they used a special algorithm to listen in on and detect pertinent conversations from smart devices in order to target ads to consumers within a specific geographic region. Contrary to these companies’ claims, however, the marketing service wasn’t based on voice data, and consumers hadn’t opted into this service. If the s[...]
: The Federal Trade Commission finalized an order with General Motors and OnStar settling allegations that they collected, used, and sold consumers’ precise geolocation data and driving behavior data from millions of vehicles without adequately notifying consumers and obtaining their affirmative consent. Under the order finalized by the Commission, General Motors LLC, General Motors Holdings LLC, and OnStar, LLC (collectively GM), which are owned by General Motors Company, are prohibited from sharing certain consumer data with consumer reporting agencies. They also are required to take steps to provide greater transparency and choice to consumers over the collection, use, and disclosure of their connected vehicle data. In a complaint first announced in January 2025, the FTC alleged that GM used a misleading enrollment process to get consumers to sign up for its OnStar connected vehicle service and OnStar Smart Driver feature. The FTC also alleged that GM failed to clearly disclose that it collected consumers’ [...]
: Today, 22 states joined the Federal Trade Commission in filing suit against Amazon, alleging that the company engaged in deceptive and unfair practices that secretly inflated prices in its online search advertising auctions. The complaint alleges that, for over seven years, Amazon has covertly and substantially increased the prices that more than one million brands and sellers were required to pay to advertise on its platform. As a result, the complaint alleges that Amazon’s scheme has likely extracted tens of billions of dollars from its unwitting advertising customers. “When one of the world’s largest online retailers engages in unfair and deceptive conduct, the impact can be staggering,” said Chairman Andrew N. Ferguson. “Amazon has millions of advertising customers who were misled into paying significantly higher prices. These higher costs were largely passed on to American consumers. The FTC under President Trump won’t allow this deception to continue.” The FTC, along with the attorneys general of Ala[...]
: Defendants behind a wide-ranging operation known as Growth Cave, including its co-CEOs, are permanently banned from marketing and selling business opportunities and credit repair programs as part of an FTC settlement to resolve allegations that their scheme cost consumers nearly $50 million. As part of that settlement, Growth Cave’s co-CEOs also will be required to liquidate millions of dollars’ worth of assets, including a multimillion-dollar house, to provide consumer redress. “On day one, the Trump-Vance FTC reprioritized combatting fraud that harms American markets. Today’s successful resolution demonstrates that the Commission is focused on protecting our markets from dishonest actors,” said Christopher Mufarrige, Director of the FTC’s Bureau of Consumer Protection. The FTC sued Growth Cave in February 2025, alleging that consumers were deceived by false promises of significant income. Growth Cave allegedly offered numerous business opportunities, which regularly failed to deliver the promised results[...]
: Brussels, 09 April - The European Data Protection Board (EDPB) has published its 2025 Annual Report . The report provides an overview of the EDPB work carried out in 2025 and reflects on important milestones, such as the adoption of the Helsinki Statement on Enhanced Clarity, Support, and Engagement . “In 2025, we saw the data protection landscape change significantly. The rapid expansion of the EU’s digital regulatory framework has added complexity to the data protection ecosystem. To help organisations navigate this complexity and support compliance, the EDPB focused on enhancing legal certainty, making compliance more achievable in practice, and strengthening cooperation, both among Data Protection Authorities and with other regulators. We also prioritised meaningful dialogue with stakeholders to ensure our work reflected real-world needs. Our achievements support economic growth while continuing to protect individuals’ fundamental rights to privacy and data protection.” EDPB Chair, Anu Talus The Hel[...]
: StubHub, the nation’s largest ticket exchange and resale ticket provider, will pay $10 million to settle Federal Trade Commission charges that the company violated the FTC Act and the agency’s Rule on Unfair or Deceptive Fees by deceptively advertising ticket prices on its website without clearly and conspicuously disclosing up-front how much consumers actually would pay, including all mandatory fees. “The Commission’s Fees Rule makes it very clear that the total price of live-event tickets must be disclosed up-front to enable consumers to make fully informed purchasing decisions,” said Christopher Mufarrige, Director of the FTC’s Bureau of Consumer Protection. “Price transparency is essential to a free and competitive marketplace. Today’s settlement underscores the Commission’s commitment to ensuring that consumers pay the price they are promised.” The FTC’s action against StubHub Holdings, Inc., follows a warning letter the agency sent the online ticket platform in May 2025 stating that multiple prices di[...]
: FTC consumer protection year in review offers 2020 vision for your business lfair January 8, 2020 | 9:26AM FTC consumer protection year in review offers 2020 vision for your business By Lesley Fair They say hindsight is 20/20, but what about foresight? We’re not ones to prognosticate, but a look at notable FTC cases and initiatives from the past year suggests some topics likely to be top of mind in months to come. Here is a non-exhaustive list of issues in our 2019 rearview mirror and likely visible through the 2020 windshield. Consumer privacy. The FTC’s $5 billion enforcement action against Facebook made history and headlines, but the other notable part of the case is the monumental change the order mandates to Facebook’s privacy ecosystem. The Commission opinion in Cambridge Analytica reaffirms the proposition that like any other claim, a company’s privacy promises are viewed through the lens of established FTC consumer perception principles. A series of cases demonstrates the agency’s continued commitmen[...]
: The Federal Trade Commission today moved to block medical device supplier Edwards Lifesciences Corp.’s (Edwards) proposed acquisition of JenaValve Technology, Inc. (JenaValve) due to concerns that the acquisition would limit patient access to lifesaving medical devices used to treat a potentially fatal heart condition. The FTC alleges that over the span of two days in July 2024, Edwards executed agreements to acquire both JenaValve and JC Medical, the two leading companies competing to bring to market transcatheter aortic valve replacement devices that treat a heart condition called aortic regurgitation (TAVR-AR devices). Edwards closed its acquisition of JC Medical in August 2024, and its proposed $945 million acquisition of JenaValve would combine the only two companies with ongoing clinical trials in the United States for a TAVR-AR device. The deal threatens to reduce competition in the TAVR-AR market, likely resulting in reduced innovation, diminished product quality, and potentially increased prices for[...]
: Brussels, 12 September - During its September plenary meeting, the European Data Protection Board (EDPB) has adopted guidelines on the interplay between the Digital Services Act (DSA) and the General Data Protection Regulation (GDPR) . These are the first set of EDPB guidelines on the interplay between the GDPR and the EU’s recently adopted digital laws. The DSA aims to complement the rules of the GDPR to ensure the highest level of protection of fundamental rights in the digital space. Its main goal is to create a safer online environment in which the fundamental rights of all users, including the right to freedom of expression, are protected. It applies to online intermediary services , such as search engines and platforms. Several provisions included in the DSA entail the processing of personal data by intermediary service providers. The EDPB guidelines contribute to the consistent application of the DSA and of the GDPR, insofar as some provisions of the DSA concern the processing of personal data by inte[...]
: BEREC presents its assessment of the Digital Networks Act proposal yannick.stephan Wed, 10/06/2026 - 18:07 Press Releases Europe’s electronic communications framework is entering a pivotal phase of reform, with the proposed Digital Networks Act (DNA ) set to update the regulatory framework for connectivity across the EU. At the BEREC public debriefing on 10 June, the BEREC Chair, Marko Mismas (AKOS, Slovenia), and the Working Group Co-Chairs presented BEREC’s assessment of the DNA proposal, outlining key regulatory considerations that emerged from its analysis. BEREC welcomes the ambition of modernising the EU connectivity framework and supporting resilient, sustainable and high-quality digital networks. At the same time, the assessment highlights areas where further refinement may be needed to ensure that the future framework strengthens rather than adds unnecessary complexity to the internal market for electronic communications. BEREC has developed thematic papers examining key elements of the proposal in [...]
: dc.contributor.author: Gonzalez Fernandez, Nadia dc.date.issued: 2026-10 dc.description.abstract: La diversité logicielle contribue à améliorer la fiabilité et la sécurité des systèmes depuis les années 1960, notamment gr'ce à des modèles dans lesquels une autorité centrale mandate et certifie des implémentations indépendantes. Au cours de la dernière décennie, Ethereum a déployé la diversité à grande échelle sous une forme nouvelle : 11 clients indépendants y coexistent sans être mandatés ni certifiés par une autorité centrale, tout en bénéficiant de la diversité déjà présente dans l’écosystème open source. Cette thèse étudie Ethereum comme un exemple de ce modèle émergent de diversité logicielle, en examinant son adoption, son étendue dans le code des clients et les défis qu’elle soulève. Nous combinons des entretiens semi-directifs avec sept contributeurs impliqués dans le développement, la coordination et le suivi de la diversité des clients, avec la première analyse statique complète de la chaîne d’appr[...]
: Amazon will pay $2.25 million in civil penalties to settle Federal Trade Commission allegations that the online retail giant knowingly violated the Fair Credit Reporting Act (FCRA) by refusing to provide transaction records to consumers whose personal information was used by identity thieves to commit fraud. The complaint , filed by the Department of Justice upon notification and referral from the FTC, alleged that in numerous instances, Amazon.com Inc. failed to comply with Section 609(e) of the FCRA, which requires companies to, within 30 days of a consumer’s request, provide victims of identity theft with application and business transaction records about fraudulent transactions made in their names. According to the complaint, Amazon had no written policy to respond to Section 609(e) requests until early 2025, after it learned of the FTC’s investigation, despite prior outreach from FTC staff advising the company to review its compliance with Section 609(e). “Amazon often put identity theft victims through[...]
: The Federal Trade Commission secured a settlement agreement with Southern Glazer’s Wine and Spirits LLC, the nation’s largest distributor of wine and spirits, that will redress allegedly illegal price discrimination practices and make it easier for small businesses to compete against large chain retailers. The sweeping settlement covers nearly all Southern wine and spirits sales to the five largest chain retailers in 26 states. The settlement will also provide direct cash payments to harmed small businesses if an independent monitor finds that Southern violates the settlement order going forward. “This settlement marks a significant milestone for the FTC in its enforcement of the Robinson-Patman Act, which Congress enacted to empower small businesses to compete against large ones,” said Daniel Guarnera, Director of the FTC’s Bureau of Competition. “Small businesses are an invaluable part of the American economy and way of life. The FTC is committed to ensuring that all businesses, no matter their size, can c[...]
: 7-Eleven, Inc. and its parent company, Seven & i Holdings Co., Ltd., (collectively 7-Eleven) will pay $4.5 million to settle a Federal Trade Commission lawsuit alleging that the convenience store chain violated a 2018 FTC consent order by acquiring a fuel outlet in St. Petersburg, Fla. without providing the Commission prior notice. The $4.5 million penalty marks the largest civil penalty ever collected in an FTC case involving a prior-notice violation. It is also the largest negotiated settlement of any order violation in the FTC Bureau of Competition’s history. “Under the Trump-Vance FTC, merger remedies that protect competition are once again on the table. But for merger remedies to work, firms must abide by the terms of their consent orders, and we will hold parties accountable when they don’t live up to their commitments,” said Daniel Guarnera, Director of the FTC’s Bureau of Competition. “7-Eleven failed to fulfill the terms of the FTC’s consent order and is now paying a record price. The FTC will not h[...]
: The Federal Trade Commission announced today that is considering whether to update its Rule on Impersonation of Government and Businesses or take other action to prevent online platforms from engaging in ad-optimization practices that may be furthering impersonation scams. In an Advance Notice of Proposed Rulemaking (ANPRM) to be published in the Federal Register , the FTC is seeking comment on the extent to which ad-optimization tools and services offered by social media, search engines and other digital marketplace platforms further efforts by scammers to impersonate legitimate businesses and government agencies using online ads. “Free markets depend on trust, transparency and consumers’ ability to make informed choices. Impersonation scams—especially when amplified by digital platforms that profit from them—do more than rob Americans of their hard-earned money,” said Christopher Mufarrige, Director of the FTC’s Bureau of Consumer Protection. “They erode the very foundation that allows competitive markets[...]
: The Federal Trade Commission today began enforcing the TAKE IT DOWN Act (TIDA), a law requiring platforms, at the request of victims, to remove intimate photos or videos shared online without victims’ consent. As part of its enforcement role, the FTC has launched TakeItDown.ftc.gov , a website allowing victims and survivors to submit complaints about platforms that have failed to act on valid requests for the removal of nonconsensual intimate images. The website also accepts complaints about platforms that have failed to create a process for people to request removal of these images. “Thanks to First Lady Melania Trump’s dedication, the public, especially children, will have recourse against digital exploitation and extortion,” said FTC Chairman Andrew N. Ferguson. “In the age of AI, anyone can be targeted, and that becomes even more appalling if children are involved. The TAKE IT DOWN Act empowers families and provides the FTC with an effective tool to protect minors against this form of abuse.” The FTC enf[...]
: The Federal Trade Commission’s initial findings from its surveillance pricing market study revealed that details like a person’s precise location or browser history can be frequently used to target individual consumers with different prices for the same goods and services. The staff perspective is based on an examination of documents obtained by FTC staff’s 6(b) orders sent to several companies in July aiming to better understand the shadowy market that third-party intermediaries use to set individualized prices for products and services based on consumers’ characteristics and behaviors, like location, demographics, browsing patterns and shopping history. Staff found that consumer behaviors ranging from mouse movements on a webpage to the type of products that consumers leave unpurchased in an online shopping cart can be tracked and used by retailers to tailor consumer pricing. “Initial staff findings show that retailers frequently use people’s personal information to set targeted, tailored prices for goods[...]
: Public consultation on the draft BEREC Work Programme 2027 yannick.stephan Thu, 01/10/2026 - 09:00 Breadcrumbs Public Consultations & Calls for Inputs Deadline to submit contributions: 31 October 2026 In January this year, BEREC adopted the Outline BEREC Work Programme 2027 , which reflected BEREC's objectives for the upcoming year. BEREC launched a first Call for inputs on the Work Programme 2027 from 27 February to 15 April. During the call for proposals, several additional actions were identified. Considering the early input received, during the 68th BEREC ordinary meetings (1-2 October 2026), the Board of Regulators adopted the draft BEREC Work Programme 2027 [BoR (26) 142] for public consultation. Background BEREC prepares its annual work programme in accordance with Article 21 of the BEREC Regulation and the BEREC Strategy 2026-2030 to guide how it organises and prioritises its work towards clearly defined objectives. The 2027 draft work programme was developed inclusively and transparently, with cont[...]
: BEREC Provides Early Assessment of the Digital Networks Act, Welcoming Ambition While Highlighting Areas for Improvement yannick.stephan Mon, 30/03/2026 - 12:57 Press Releases The Body of European Regulators for Electronic Communications (BEREC) today published its early assessment of the European Commission’s proposal for a Digital Networks Act (DNA). BEREC welcomes the overarching ambition to modernise the regulatory framework for Europe’s connectivity sector and to support resilient, sustainable and high quality digital networks. At the same time, BEREC identifies important areas where further refinement is needed to ensure that the DNA strengthens, rather than complicates, Europe’s internal market for electronic communications. BEREC stands ready to provide its regulatory expertise in order to avoid undue complexity or uncertainty and to ensure that the final framework delivers a competitive, connected and resilient digital Europe. BEREC welcomes the updated objectives introduced by the DNA , including r[...]
: The Federal Trade Commission is returning nearly $23 million to consumers nationwide who bought deceptively marketed overseas real estate lots in what the sellers pitched as Sanctuary Belize, a supposed luxury development in southern, coastal Belize, as well as its nearby sister development, Kanantik. The FTC is mailing 1,659 checks to defrauded investors. The average amount of each check for Sanctuary Belize consumers is $16,462 and the average amount of each check for Kanantik consumers is $6,346.39. Today’s announcement represents the second mailing to consumers who invested in the Sanctuary Belize scheme, with approximately $10 million distributed previously . The first round of checks was sent only to consumers who bought property within Sanctuary Belize. Today’s checks are going to both Sanctuary Belize investors, as well as consumers who invested in Kanantik, a related development owned and operated by some of the Sanctuary Belize defendants, and other areas covered by the court relief in this case. [...]
: Public consultation on the draft BEREC Report on Virtual Worlds and Web 4.0 yannick.stephan Tue, 17/03/2026 - 09:26 Breadcrumbs Public Consultations & Calls for Inputs Deadline: Monday, 20 April 2026 (17:00 CEST) During the 66th BEREC plenary meeting (12-13 March 2026), the Board of Regulators approved the Draft BEREC Report on Virtual Worlds and Web 4.0 (BoR (26) 39) for public consultation. The report in a nutshell Virtual worlds (VW) and web 4.0 are at the basis of a transition to the 4th generation of internet based services, leading toward industry 4.0 and smart society. This shift is driven by artificial intelligence (AI) integration in networks and services. Hence, web 4.0 and immersive services are meant to have a significant economic and social impact by transforming the way in which industrial production evolves and automates its processes. At the same time, they transform the fruition of online content and applications by users. This draft BEREC Report provides a fully-fledged analysis. The first [...]
: New data from the Federal Trade Commission reveal that people reported losing a staggering $3.5 billion to imposter scams in 2025, with reported losses increasing nearly three times since 2020. FTC data also show that people reported imposter scams more than any other fraud category in 2025—nearly one in three fraud reports were about imposter scams. These scams lured consumers through text, phone, email, social media, search engine results and other means. Some of the costliest impersonation scams start with a fake security alert, often from a bank. People are convinced to move money to “protect” it, with their losses often limited only by their available funds. Last year, people reported losing nearly $1 billion to business impersonators with the highest reported losses to bank impersonators—and about $920 million to government impersonators, up from $866 million and $789 million respectively in 2024. The FTC has seen a striking increase in reported fraud losses to all types of fraud—about $16 billion was [...]
: FTC challenges Online Trading Academy’s money-making claims lfair February 12, 2020 | 4:35PM FTC challenges Online Trading Academy’s money-making claims By Lesley Fair Ads for health products often target Boomer Consumers, but those aren’t the only claims pitched to people looking toward retirement. An FTC action alleges a company called Online Trading Academy has taken in more than $370 million by gearing its deceptive representations to that demographic. In addition, the complaint alleges violations of the Consumer Review Fairness Act. According to the FTC, the California-based operation, related companies, and three individual defendants advertise a “patented strategy” that consumers can apply “to any asset class including stocks, options, futures and currencies” to rake in big money. They claim their “training programs” – with price tags as high as $50,000 – will teach consumers how to “invest like the pros on Wall Street.” ”No matter your experience and goals,” people were told the defendants’ “proven” [...]