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SEC OCIE Issues 2020 Examination Priorities

On January 7, the SEC’s Office of Compliance Inspections and Examinations (OCIE) announced its 2020 national examination priorities. This is the eighth year that OCIE has published its fiscal year examination priorities. ...more

Consultants, Investment Advisers, and Compliance

It is important for registered investment advisers to determine if the correct workers – regardless of employee or consultant labels — have been designated as Access Persons. Originally published as a guest post on Hedge...more

FinCEN Proposed AML Rule for Registered Investment Advisers Remains on Track for 2016 Adoption

There are a number of issues that FinCEN must still address, but comments to the proposed rule do not raise any material issues that will prevent the agency from issuing a final rule in 2016. The Financial Crimes...more

FinCEN's Recently Proposed AML Rule: A Road Map for SEC-Registered Investment Advisers

The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (the Proposed Rule) on September 1, 2015 that would impose anti-money laundering (AML) requirements for investment...more

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