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The Latest in the SEC’s Off-Network Communications Enforcement Sweep

On September 29, 2023, the U.S. Securities and Exchange Commission (SEC) announced enforcement actions against five broker-dealers, three dually registered broker-dealers and investment advisers, and two affiliated investment...more

$1.8 Billion in SEC and CFTC Fines Highlights Continued Scrutiny of Unapproved Messaging Platforms

Federal enforcement agencies continue to scrutinize investment advisers’ use of personal devices and messaging platforms to conduct business. Our team reviews how recent penalties should encourage companies to create internal...more

SEC Sends a Message to Investment Advisers: Take Secure Data Disposal Seriously

On September 20, 2022, the Securities and Exchange Commission (SEC) settled an enforcement action with a large, registered investment adviser (the Firm) for alleged violations of the Safeguards Rule and the Disposal Rule of...more

SEC Settles Enforcement Actions with Broker-Dealers and Investment Advisors for Identity Protection Deficiencies

On July 27, 2022, the Securities and Exchange Commission (SEC) separately settled three enforcement actions with broker-dealers and investment advisers for alleged deficiencies relating to the prevention of customer identity...more

SEC Cements Expectations for Investment Advisers’ and Investment Companies’ Cyber Preparedness and Disclosure

Our Privacy, Cyber & Data Strategy and Investment Management, Trading & Markets Teams review the Securities and Exchange Commission’s potentially transformative proposed rules that would require registered investment...more

SEC Issues Risk Alert Noting Common Regulation S-P Compliance Issues

The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has issued a Risk Alert that provides an overview of the most common deficiencies or weaknesses in investment adviser and broker-dealer compliance with the...more

SEC Prioritizes Data Security and Expects More Mature Cybersecurity Programs

Investment advisers and broker-dealers can expect more scrutiny of their data security from the Securities and Exchange Commission. Our Cybersecurity Preparedness & Response and Investment Management, Trading & Markets teams...more

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