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SEC Issues Risk Alert on Observations from Examinations of Newly-Registered Advisers

On March 27, 2023, the SEC’s Division of Examinations (the “Division”) issued a Risk Alert on its observations from examinations of newly-registered advisers. The Division focused on whether newly-registered advisers...more

SEC Exams of Advisers and Investment Companies

The Division of Examinations has revamped and updated its exam priorities according to its most recent release, 2023 Exam Priorities. Consistent with its typical approach the Division plans to focus on a blend of topics and...more

Federal Enforcement Forum: EXAMS - Implementing Reg NMS Rule 606

Rule 606: EXAMS – the Division of Examinations – published a Risk Alert on November 10, 2022, providing its Observations Related to Regulation NMS Rule 606 Disclosures. That Rule requires broker-dealers to provide enhanced...more

The New Adviser Marketing Rule: Division of Examinations Alert

​​​​​​​The Division of Examinations issued a Risk Alert on September 19, 2022 focused on Advisers Act Rule 206(4)-1, the Advertising Rule, adopted on December 22, 2020. The Rule becomes effective on November 4, 2022....more

SEC Enforcement: A Brief Review of 1Q22

Analyzing the trends of SEC enforcement is key for many companies, particularly when evaluating their compliance systems. The work of the Enforcement Division during the first quarter of 2022 should be considered in the...more

SEC Exam Priorities 2022 and Compliance

The Division of Examinations announced its 2022 Exam Priorities in a release dated March 30, 2022. The 2022 priorities are, as usual, a blend of traditional considerations from past programs mixed with new and at times...more

The New SEC Enforcement Program: Trust & Fairness

Last week new enforcement director Gurbir Grewal made his first public remarks at PLI’s SEC Speaks 2021 (October 13, 2021). Mr. Grewal is the former Attorney General of New Jersey....more

SEC’s Division of Exams on AML Compliance

Money laundering compliance is a critical area for banks, broker-dealers and others in the financial world. The importance of this area was recently highlighted by the passage of the Corporate Transparency Act or CTA to...more

The SEC and SARs

The Commission periodically has filed enforcement actions against broker-dealers for failing to file SARs - suspicious activity reports - typically centered on a failure to file reports regarding microcap issuers. Those...more

SEC on Compliance

Compliance is a key issue for all firms. Many companies use the U.S. sentencing guidelines as a starting point. In other instances, regulators craft a starting point with rules that direct the creation of programs....more

OCIE Observations on Supervision and Compliance for Branch Offices

The Commission’s Office of Compliance Inspections and Examinations or OCIE issued a Risk Alert on November 9, 2020 centered on questions keyed to supervision and compliance in the context of multiple branch advisories. The...more

First DOJ FCPA Opinion in Six Years

The Department of Justice issued its first FCPA opinion in six years on August 14, 2020. Foreign Corrupt Practices Act Review, Opinion Procedure Release, No.: 20-01. The opinion process provides a mechanism by which a...more

The First OCIE Inspection of Brokers Re Regulation Best Interest

Regulation Best Interest, born of a long debate over the appropriate standard to govern recommendations by broker-dealers, is now the subject of an OCIE Risk Alert.  The staff is preparing to launch its first inspection for...more

SEC Exam Priorities For RIAs and ICs

The Exam Priorities of the SEC’s Office of Inspections and Compliance or OCIE, announced on January 7, 2020 (the “Exam Priorities”), should be a key area of focus for every investment advisor and investment company. The Exam...more

Facilitating FCPA Enforcement Through International Cooperation

SEC Chairman Jay Clayton called for greater international cooperation in the enforcement of anti-corruption statutes such as the Foreign Corrupt Practices Act in remarks delivered before the Economic Club of New York on...more

DOJ and Compliance

The Department of Justice and the Securities and Exchange Commission have repeatedly focused on corporate compliance in recent years as a way to mitigate liability.  Neither the DOJ nor the SEC is about to recognize a...more

The SEC's National Exam Program 2019

The SEC's Office of Compliance Inspections and Examinations (“OCIE” or the “Office”) announced its 2019 Examination Priorities just before Christmas and the current Government partial-shutdown (here). While nonemergency...more

The FCPA and Foreign Nationals

Despite the fact that the Foreign Corrupt Practices Act has been in force for decades there is relatively little case law interpreting its provisions. A great deal of the existing interpretation of the Act stems from...more

Dorsey Anti-Corruption Digest - January 2018

Keeping ahead of global anti-corruption trends is critical in today’s business markets. The Dorsey Anti-Corruption Digest, which puts global trends at your fingertips, puts you ahead. The deep experience of the Dorsey...more

Dorsey Anti-Corruption Digest - December 2017

Deputy Attorney General Rod Rosenstein announced the addition of a new Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) policy, titled the FCPA Corporate Enforcement Policy. The new policy, which was...more

Lessons From the Market Place: The Importance of Compliance

An effective program is a key corporate function of increasing importance. It can be a competitive advantage, creating a tone of excellence which permeates the firm’s culture, products, services and customer relations....more

Dorsey Anti-Corruption Digest - September 2017

Keeping ahead of global anti-corruption trends is critical in today’s business markets. The Dorsey Anti-Corruption Digest, which puts global trends at your fingertips, puts you ahead. The deep experience of the Dorsey...more

Dorsey Anti-Corruption Digest - August 2017

The Department of Justice (DOJ) ended its probe of Net1 UEPS Technologies, according to SEC filings from the South African-based payment processing company. The company received a declination from the Securities and Exchange...more

Anti-Corruption Digest - July 2017

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. The Digest puts material regarding anti-corruption enforcement from around the world at your fingertips, keeping you ahead of critical events that impact global...more

Effective FCPA Compliance Programs: Building a Compliance Defense

The classic 1957 American mystery film “Three Faces of Eve,” about a woman with multiple personalities, may well describe the approach taken by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange...more

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