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Policies and Procedures Investment Adviser Enforcement

Cozen O'Connor

Breaking Down the SEC Examinations Process: Key Considerations for Registrants, Part 1

Cozen O'Connor on

In a two-part legal update, we will discuss key information SEC registrants should know going into the upcoming review cycle conducted by the Division of Examinations (the Division). This first update attempts to demystify...more

K2 Integrity

Implementing FinCEN Final Rule Imposing Anti-Money Laundering Requirements On Investment Advisers

K2 Integrity on

On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...more

Seward & Kissel LLP

Continued SEC Enforcement Actions Relating to Off Channel Communications

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Who may be interested: Registered Investment Advisers, Registered Investment Companies, Compliance Staff - Quick Take: The SEC recently announced a number of additional enforcement actions relating to recordkeeping...more

Proskauer - The Capital Commitment

Mid-Year Enforcement Update: SEC’s Continued Focus on Private Funds in 2024

As we reach the midpoint of 2024, the SEC has maintained its rigorous enforcement stance on the private funds industry, proposing new rules and oversight tools to better identify and investigate market practices. As 2024...more

Proskauer - The Capital Commitment

Cybersecurity Continues to be a Focal Point for Regulators in 2024

The SEC’s new and proposed rules on cybersecurity and cyber-incident reporting will have a dual impact on private investment advisers and funds. First, the proposal by the SEC will impose cybersecurity related...more

Freiberger Haber LLP

Enforcement News: SEC Charges Investment Advisor With Violating Whistleblower Protection Rule

Freiberger Haber LLP on

We have often written about the SEC’s whistleblower program and, in particular, the success of the program with respect to detecting and preventing violations of the federal securities laws. The success of the program...more

Akin Gump Strauss Hauer & Feld LLP

The Latest Settlements in the SEC’s 'Off-Channel' Communications Sweep: What This Means and What’s Next

Key Points - Last week, the SEC announced settlements with 10 broker-dealers and affiliated investment advisers in connection with their failures to maintain and preserve electronic “off-channel” communications....more

Seward & Kissel LLP

SEC Enforcement of Off-Channel Communications Continues - New Series of Firms Charged with Penalties Totaling $289 Million

Seward & Kissel LLP on

Summary of the Recent SEC Actions - On August 8, 2023, in yet another set of enforcement actions in the space, the U.S. Securities and Exchange Commission (the “SEC”) settled charges against ten broker-dealers and a dually...more

ArentFox Schiff

Newly Registered Investment Advisors Tread Carefully: SEC Issues Risk Alert

ArentFox Schiff on

On March 27, the US Securities and Exchange Commission (SEC) released a risk alert focusing on the SEC’s conclusions after its routine examination of newly registered investment advisors....more

Proskauer - The Capital Commitment

SEC Revisits Regulation S-P After Twenty Years of Innovation to Information Technology

On March 15, 2023, the U.S. Securities and Exchange Commission (“SEC”) released its proposal to amend Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Customer Information (the “Proposed...more

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