Episode 116 -- Alstom Executive Convicted of FCPA and Money Laundering Offenses
Opinion Release Papers-07-01-Travel for Foreign Officials
[WEBINAR] Who Does What? Defining Proper Roles for Staff and Elected Officials
FCPA Compliance and Ethics Report-Episode 109-interview with Bill Michael on the SEC FCPA enforcement action against FLIR employees
On August 19, 2024, the U.S. Securities and Exchange Commission (SEC) settled with a registered investment adviser (Adviser),1 whereby the Adviser paid a $95,000 civil money penalty in addition to being censured for...more
Kamala Harris’ selection of Tim Walz as running mate for her presidential campaign has implications under the Securities and Exchange Commission’s (SEC) Rule 206(4)-5 under the Investment Advisers Act (SEC Pay-to-Play Rule)....more
On August 6, 2024, the Democratic nominee for President, Kamala Harris, chose Tim Walz, Governor of Minnesota, as her running mate. This selection presents important considerations vis à vis the “Pay-to-Play Rule” (Rule...more
Vice President Kamala Harris’ selection of Minnesota Governor Tim Walz as her running mate highlights a wrinkle in Investment Advisers Act Rule 206(4)-5 (the “Pay-to-Play Rule” or “Rule”) to which investment advisers should...more
On April 15, 2024, the SEC announced the settlement of administrative proceedings brought against a registered investment adviser for alleged violations of Section 206(4) of the Investment Advisers Act of 1940 and Rule...more
After recently signing legislation allowing state officeholders to run for president without resigning from office, Florida Gov. Ron DeSantis has officially entered the 2024 presidential race. As a sitting governor, DeSantis...more
The District of Columbia’s long-awaited pay-to-play law will take effect on November 9, 2022, after over two years of delay. The District’s pay-to-play law was originally set to go into effect on November 4, 2020, but was...more
Many states and municipalities have adopted laws and regulations that affect how investment managers may solicit investment advisory business, including investment in sponsored public and private funds, from the state...more
On January 17, 2017, the SEC announced nine settled enforcement actions for violations of the pay-to-pay rule against private equity, venture capital and hedge fund sponsors. The firms involved agreed to pay monetary...more
As the elections approach nationwide, advisers to private investment funds with current or prospective state or local government entity investors should be mindful of political activities by their personnel which could raise...more
Regulatory Developments - CFTC Issues Proposed Amendments to Swap Data Recordkeeping and Reporting Requirements for Cleared Swaps: On Aug. 19 the CFTC announced that it had voted to propose amendments to existing...more
The DC Circuit Court has rejected an effort by the New York and Tennessee Republican Parties to set aside Securities and Exchange Commission Rule 206(4)-5. The 2010 SEC rule prohibits investment advisers from providing...more