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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more
On October 26, the SEC proposed a new Advisers Act rule (the “Proposed Rule”) that would establish specific obligations for Registered Investment Advisers with respect to outsourcing of “Covered Functions”, as that term is...more
On October 26, the Securities and Exchange Commission (SEC) issued a rule release (Release) that proposed new and amended rules (Proposed Rule) under the Investment Advisers Act of 1940, as amended (Advisers Act)....more
On October 26, 2022, the US Securities and Exchange Commission (the "SEC") proposed a new rule (206(4)-11) and amendments under the Investment Advisers Act of 1940 that prohibit registered investment advisers from outsourcing...more
On October 26, 2022, the U.S. Securities and Exchange Commission (SEC) proposed new Rule 206(4)-11 (the “Vendor Oversight Rule” or the “Rule”) to prohibit investment advisers registered under the Investment Advisers Act of...more
The United States represents a large source of potential capitalthat non-U.S. fund managers often find impossible to ignore. To assist non-U.S. fund managers, we have prepared a checklist that sets out key considerations for...more
On January 7, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) announced its 2020 examination priorities for regulated entities, including investment advisers and registered funds. The examination...more
On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more