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Risk #6: Valuation Under Pressure: Market Stress and the Enforcement Lens

Markets have recently been experiencing heightened volatility and credit availability has tightened, which has placed valuation practices under unusual pressure from regulators and investors. The events of the past several...more

Risk #5: Private Litigation Risk for GP-Led Secondary Transactions

GP-led secondary transactions continued to soar in popularity in 2025. With mixed economic indicators potentially impeding other kinds of private equity exit events, the uptick in continuation funds shows no signs of slowing...more

Risk #4: Five Guidelines for ESG Disclosures in 2026: Choose Your Words Carefully

Choose your words carefully because careless words cost. Never has this been more true than in disclosures about environmental, social and governance matters. As divergence between the US federal government and “red...more

Risk #3: Five Considerations for Advisers Implementing AI in Investment Decisions

Use of technology referred to as “artificial intelligence” is fast finding its way into many aspects of commercial life. Registered investment advisers are no exception as AI tools are already being used for screening and...more

Risk #2: AI Infrastructure Investing: Structuring, Disclosure and Contract Risks for Private Funds

As has been widely reported, digital infrastructure has become one of the fastest growing investment structures in recent years, most recently driven by the explosion in demand from firms in the artificial intelligence (AI)...more

Risk #1: Private Credit under the Microscope – Why Vigilance Matters

Private credit has spent a decade rising from niche alternative to central pillar in global finance. It has become a multi-trillion-dollar engine of corporate lending, infrastructure finance, asset-based credit, specialty...more

Top Ten Regulatory and Litigation Risks for Private Funds in 2026

If we had to define the mood for 2026 in three words, we would choose alert, intentional and institutional. After several years of normalizing longer hold periods and navigating evolving regulatory frameworks, 2026 will see...more

Do Your Insider Trading Policies Cover The Prediction Markets? Should They?

Prediction markets now offer contracts tied directly to public company events—including stock price movements, earnings call language, regulatory outcomes, corporate announcements, and management decisions. These contracts...more

Michigan Federal Court Protects AI-Assisted Litigation Work Product

Courts issued two seemingly conflicting rulings on whether AI generated materials are protected. Heppner (S.D.N.Y.) found that documents created with a consumer version of Claude AI were not privileged or work product because...more

Delaware Chancery Litigation Over Continuation Vehicle Transaction Highlights Considerations for GP-Led Secondaries

An action filed in late November 2025 in the Delaware Court of Chancery by an investor in a private equity fund highlights the potential risks to fund sponsors when investors are dissatisfied with continuation vehicle (“CV”)...more

Delaware Chancery Litigation Highlights Considerations for GP-Led Secondaries

An action filed last month in the Delaware Court of Chancery by an investor in a private equity fund highlights the potential risks to fund sponsors when investors are dissatisfied with continuation vehicle (“CV”)...more

2026 SEC Examination Priorities for Investment Advisers – Same Tune, New Notes

On November 17, 2025, the SEC’s Division of Examinations released its 2026 Examination Priorities (“Priorities”).  Despite a shift in “tone at the top” under Chair Atkins, the Priorities indicate that the Division will...more

SEC v. TZP Management Associates, LLC: Insights Into Private Fund Enforcement Priorities Under Chair Atkins

On August 15, 2025, the Securities and Exchange Commission (“SEC”) issued an order settling proceedings against TZP Management Associates, LLC (“TZP”) for allegedly miscalculating management fee offsets between 2018 and 2023....more

SEC Cites Falsified Compliance Records in Two Recent SEC Settlements with CCOs

Two SEC enforcement actions from earlier this month, each including charges against a firm’s Chief Compliance Officer in their personal capacity, underscore the importance of maintaining accurate records and upholding...more

Seven Questions for Legal and Compliance Before Adopting AI Transcription Services

As businesses accelerate their use of automated tools to record and transcribe meetings, risks are growing. The use of these “AI tools” to transcribe meetings, such as witness interviews, expert network calls, investment...more

FCPA & Anti-Corruption Enforcement: Shifting Global Dynamics in Light of New U.S. Regime

The last two decades have been marked by robust enforcement of the U.S. Foreign Corrupt Practices Act (“FCPA”) by the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”). In line with its “shock...more

Protecting Sponsors from Emerging Portfolio Company Risks through Insurance

In addition to the normal operational and legal risks associated with owning and managing portfolio companies, 2025 has introduced or exacerbated a wave of geopolitical and macroeconomic risks such as inflation, tariffs,...more

Why the DOJ’s New Whistleblower Program Remains Relevant

On May 12, 2025, the U.S. Department of Justice (DOJ) issued a memorandum outlining the Criminal Division’s enforcement priorities and policies for prosecuting corporate and white-collar crimes in the new Administration....more

Navigating Earn-Out Disputes: Key Considerations for Private Funds

Times of economic volatility often increase disparities between a seller’s valuation and the buyer’s valuation of the same company. Earn-out provisions are one tool frequently used to address such disparities. An earn-out...more

Three Risks to Monitor in Private Credit

Private credit has become an essential source of financing globally, with fund sponsors enjoying strong demand from borrowers, market participants, and investors.  However, as the industry’s “golden age” continues, regulatory...more

End of (Fund) Life Issues

Amid a challenging environment for exits, especially in the wake of the recent market volatility, private fund managers continue to pursue alternative strategies, such as term extensions and liquidity solutions, to ride out...more

Global Trade in 2025: Outbound Investment Restrictions

Motivated by a rapidly evolving geopolitical climate, governments around the globe have increasingly scrutinized and intervened in transactions under foreign direct investment (FDI) screening regimes in recent years. Rising...more

SEC Regulation in a Non-Regulatory Environment

With Paul Atkins as the new SEC Chair, the agency’s priorities have shifted away from many of the aggressive policies of former Chair Gensler. The first four months of the Republican controlled SEC saw a dramatic shift in the...more

Regulatory Scrutiny on Potential MNPI in the Credit Markets

Over the past year, regulatory scrutiny of the credit markets has intensified, with the SEC investigating the potential use of material nonpublic information (“MNPI”) relating to credit instruments. The SEC brought a number...more

ESG in 2025: Finding the Sweet Spot in a Complex World

With ESG regulation now well embedded across all major jurisdictions, the trend we see for 2025 is about increasingly sophisticated triangulation by private fund managers between the regimes that apply by default (such as...more

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