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FinCEN Proposes AML Requirements for Certain Investment Advisers

On February 13, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (the “Proposed Rule”) that would subject registered investment advisers (“RIAs”) and...more

Compliance Dates for Final Rules Regarding the Regulation of Private Fund Advisers

On August 23, 2023, the Securities and Exchange Commission (the “SEC”) adopted new final rules and amendments to existing rules under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) with respect to the...more

The SEC Adopts Final Rules Regarding the Regulation of Private Fund Advisers

On August 23, 2023, by a vote of 3-2, the Securities and Exchange Commission (the “SEC”) adopted new final rules and amendments to existing rules under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) with...more

SEC Updates FAQ Regarding Marketing Rule Compliance – Displays of Gross and Net Performance

On January 11, 2023, the staff of the Division of Investment Management of the Securities & Exchange Commission (the “Staff”) updated its Frequently Asked Questions (“FAQ”) relating to compliance with Rule 206(4)-1 under the...more

Relocation of a Private Fund Manager: Issues to Consider

In the wake of the coronavirus-induced lockdown and the realization that technology allows firms to operate virtually anywhere, many private fund managers have relocated their headquarters to other locations in order to take...more

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