Episode 342 -- How to Conduct an Internal Compliance Site Visit and Review
Public-Private Partnerships
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Investigations and Cognitive Interviews
Episode 337 -- Nicolas Garcia, GC at Orica, on Compliance Trends and Challenges in Latin America
Implications of the SEC Cybersecurity Disclosure Rule
The Privacy Insider Podcast Episode 4: Don't Be Evil: In the Hot Seat of Data Privacy, Part 1
Privacy Issues from Third-Party Website Tags
Episode 331- NAVEX State of Risk and Compliance Programs
What the Board Should Be Asking About the Compliance Program
Managing Social Media Risk
Compliance Lessons from Dating in Your 50s
Managing Compliance Risk for Human Trafficking and Modern Slavery
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
False Claims Act Insights - The Art and Science of Corporate Compliance in Managing FCA Risk
Preparing for a Government Healthcare Audit
Episode 318 -- LRN's Recent Study Underscores Importance of Ethical Culture and Values-Based Leadership
Understanding the HHS OIG’s General Compliance Program Guidance
Climate Risk, the emerging risk
What's Going on with FCPA?
Most compliance officers struggle to determine whether they are conducting enough testing to satisfy their obligations under the Advisers Act. In its release adopting Advisers Act Rule 206(4)-7, the SEC stated that an...more
SEC’s Division of Examinations (“EXAMS”) issued a risk alert on its Initial Observations Regarding Advisers Act Marketing Rule Compliance (the “Risk Alert”), giving compliance officers an unexpected gift by sharing examples...more
Many chief compliance officers struggle every year with preparing the annual review required under Advisers Act Rule 206(4)-7. To help you out, here’s our guide to writing your annual report....more
Key Points - On February 13, 2024, FinCEN issued an NPRM that seeks to include certain investment advisers in the definition of “financial institution” under the BSA. As described in the NPRM as well as in FinCEN’s fact...more
On December 5, 2022, the SEC filed a settled action against investment advisory firm Two Point Capital Management Inc. (the Firm) and its chief executive officer, who also served as the Firm’s chief compliance officer until...more
Rule 38a-1 under the Investment Company Act of 1940 (the 1940 Act) requires funds to review their compliance programs, as well of those of their service providers, including their investment advisers (advisers), annually....more
On November 19, 2020, the SEC published a risk alert providing an overview of notable compliance issues identified by the agency’s Office of Compliance Inspections and Examinations (“OCIE”) under Rule 206(4)-7 (the...more
On September 12, 2019, the Commodity Futures Trading Commission (CFTC) announced a settlement with Phillip Capital Inc. (PCI or the “Company”), a registered futures commission merchant (FCM), after hackers successfully...more
A recent settled SEC order, In re Arlington Capital Management, Inc. and Joseph F. LoPresti, highlights the potential benefits of voluntarily taking steps to remediate conduct or practices that could run afoul of the SEC’s...more
Registered investment advisers (RIAs) are required to review their policies and procedures on at least an annual basis. As an aid to the required review and to assist with timely completion of required compliance tasks, below...more
On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released proposed rules that would require investment advisers that are registered or required to be registered (RIAs)...more
How should fund directors monitor gifts and entertainment received by investment adviser personnel? This question moved to the forefront in February, when the Securities and Exchange Commission’s Division of Investment...more
SEC Commissioner Daniel Gallagher published a statement explaining his dissent in two recent enforcement actions in which the Chief Compliance Officer of an investment adviser was charged, noting that the trend in such...more
Fund compliance policies and procedures should address the receipt of gifts or entertainment by fund advisory personnel, according to guidance published by the SEC’s Division of Investment Management....more
Introduction - Registered investment advisers are required to review their policies and procedures on at least an annual basis. As aid to the required review, below is a summary of material developments during the past...more