On August 19, 2024, the U.S. Securities and Exchange Commission (SEC) settled with a registered investment adviser (Adviser),1 whereby the Adviser paid a $95,000 civil money penalty in addition to being censured for...more
9/5/2024
/ Campaign Contributions ,
Closed-End Funds ,
Federal Elections ,
Government Entities ,
Government Officials ,
Investment Adviser ,
Pay-To-Play ,
Policies and Procedures ,
Political Contributions ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC)
On May 14, 2024, the U.S. Securities and Exchange Commission (SEC) announced a settlement with a registered investment adviser (Adviser) that found the Adviser had (a) failed to adequately disclose conflicts pertaining to...more
Rule 206(4)-1, as amended (the Marketing Rule), continues to be an area of focus for the U.S. Securities and Exchange Commission (SEC). On April 17, 2024, the SEC Division of Examinations (Division) published a risk alert...more
On April 15, 2024, the U.S. Securities and Exchange Commission (SEC) settled with a registered investment adviser (Adviser), whereby the Adviser paid a $60,0000 civil money penalty of in addition to being censured for...more
On April 5, 2024, a jury found Matthew Panuwat civilly liable for insider trading in violation of federal securities laws in a first-of-its-kind “shadow trading” case (also referred to as “sympathy trading”), which was...more
The United States Department of the Treasury (U.S. Treasury) announced that it aims to publish a proposed rule in early 2024 (the 2024 NPRM) that would subject investment advisers to the anti-money laundering (AML)...more
On August 1, a bipartisan bill was introduced to modify the Corporate Transparency Act (CTA). The Protect Small Businesses and Prevent Illicit Financial Activity Act (H.R. 5119) was introduced in the U.S. House of...more
Founders and operators, is your company prepared to report its Beneficial Ownership Information (BOI)? Unless an exemption applies, you may be required under the Corporate Transparency Act (CTA) to identify and report the...more
U.S. hedge funds, private equity funds, and venture capital funds (collectively, the Private Funds)2 and their U.S. general partners, sponsors, and managers (Advisers) are not directly subject to the Bank Secrecy Act of 1970...more
7/26/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
FATF ,
Fund Managers ,
Hedge Funds ,
Office of Foreign Assets Control (OFAC) ,
Politically Exposed Person (PEPs) ,
Popular ,
Private Funds ,
Red Flags Rule ,
SDN List ,
Venture Capital
On September 29, 2022, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule implementing the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements...more
4/6/2023
/ Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Corruption ,
Exemptions ,
Final Rules ,
FinCEN ,
Fraud ,
IRS ,
Ownership Interest ,
Popular ,
Reporting Requirements ,
Smaller Reporting Companies ,
Tax Exemptions ,
Terrorism Funding
A little over a week has passed since the Federal Deposit Insurance Corp. (FDIC) became receiver of Silicon Valley Bank (SVB) and Signature Bank (Signature), and since the issuance of the joint statement by the FDIC, the U.S....more
Silicon Valley Bank, Santa Clara, California, was closed on March 10 by the California Department of Financial Protection and Innovation (CDFPI). On March 12, the New York State Department of Financial Services (NYSDFS)...more
I. Introduction-
U.S. hedge funds, private equity funds, and venture capital funds (collectively, the Private Funds),1 and their U.S. general partners, sponsors, and managers (Advisers), are not directly subject to the...more
2/20/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
FinCEN ,
Fund Managers ,
Hedge Funds ,
Investment Adviser ,
Money Laundering Control Act (MLCA) of 1986 ,
Office of Foreign Assets Control (OFAC) ,
Private Funds ,
Securities and Exchange Commission (SEC) ,
Venture Capital
On January 18th, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first action (the Order) pursuant to Section 9714 of the Combating Russian Money Laundering Act1 to designate...more