On April 6, 2018, the Office of Foreign Assets Control (OFAC) of the U.S. Treasury Department sanctioned a number of Russian businessmen and companies, as well as Russian government officials and two state-owned entities. The...more
If you read one thing. . .
- On January 1, 2016, the Common Reporting Standard (CRS) enters into effect in key investment fund jurisdictions, including the Cayman Islands, Bermuda and the British Virgin Islands.
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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
10/20/2015
/ Affiliates ,
Alternative Investment Fund Managers Directive (AIFMD) ,
Bank Secrecy Act ,
Chief Compliance Officers ,
Compliance ,
Conflicts of Interest ,
CPO ,
Cybersecurity ,
Department of Justice (DOJ) ,
Export Controls ,
FATCA ,
FinCEN ,
Foreign Affiliates ,
Foreign Investment ,
General Solicitation ,
Investment Adviser ,
Investment Funds ,
Patriot Act ,
Policies and Procedures ,
Private Funds ,
Proxy Voting Guidelines ,
Reporting Requirements ,
Securities ,
Securities and Exchange Commission (SEC) ,
Social Media Policy ,
Whistleblowers
The Bureau of Economic Analysis of the U.S. Department of Commerce requires all U.S. persons that own or control more than 10 percent of the voting securities (a “Direct Investment”) of a “foreign” business enterprise to...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
10/6/2014
/ Affiliates ,
Alternative Investment Fund Managers Directive (AIFMD) ,
Broken Windows ,
Chief Compliance Officers ,
CPO ,
Cybersecurity ,
Export Controls ,
FATCA ,
Foreign Affiliates ,
Foreign Investment ,
General Solicitation ,
Investment Adviser ,
Policies and Procedures ,
Private Funds ,
Proxy Voting Guidelines ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Social Media Policy
The staff of the Commodity Futures Trading Commission (CFTC) published a no-action letter on September 9, 2014 (available here) that permits certain commodity pool operators (CPOs) to conduct general solicitation in private...more
9/12/2014
/ CFTC ,
CPO ,
Disclosure Requirements ,
Exemptions ,
General Solicitation ,
JOBS Act ,
No-Action Letters ,
Private Offerings ,
Reporting Requirements ,
Rule ,
Rule 144A ,
Rule 506(c) ,
Securities and Exchange Commission (SEC)
The U.S. Department of the Treasury requires U.S. resident issuers (including U.S. resident investment funds) and investment advisers managing foreign investment funds to report foreign residents’ holdings of U.S. securities,...more