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Compliance Department of Justice (DOJ) Investment Adviser

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - August 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Paul Hastings LLP

Ephemeral Messaging at the Office: Avoiding Pitfalls and Establishing Best Practices

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Users of ephemeral messaging applications may intend that their messages be—as the word “ephemeral” suggests—short lived, but the real-world consequences and legal ramifications from improper use of such apps can be anything...more

A&O Shearman

U.S. Investment Firm Enters $6 Billion Parallel Resolutions With DOJ And SEC Over Allegations Of Fraudulent Conduct By Employees...

A&O Shearman on

On May 17, 2022, the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) announced parallel resolutions with a registered investment advisor (the “Advisor”), resolving criminal and civil...more

Lowenstein Sandler LLP

2020 and Q1 2021 Developments And Annual Compliance Checklists

Summaries of recent legislative and regulatory developments with respect to: •The SEC’s Examination Priorities for 2021- •The SEC’s Focus on Digital Asset Securities- •The SEC’s New Marketing Rule... ...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on New Rule 3241 from FINRA, Requests for Comment from the SEC on Money...

BROKER-DEALER - FINRA New Rule 3241 Becomes Effective February 15 - On February 15, Financial Industry Regulatory Authority (FINRA) new Rule 3241 — “Registered Person Being Named a Customer’s Beneficiary or Holding a...more

UB Greensfelder LLP

SEC Settlement Proves That When CCOs Spot A Problem, Silence Is Not Golden

UB Greensfelder LLP on

A long time ago, long before there existed any whistleblower statutes, I had a client – a CCO of a broker-dealer – who discovered some pretty funky trading at his firm. As he tells the story, when he went to see his boss (who...more

Lowenstein Sandler LLP

The SEC Identifies Common Investment Adviser Compliance Program Deficiencies Consistent With Deficiencies Recognized By Other...

Lowenstein Sandler LLP on

On November 19, 2020, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) released a risk alert (the Risk Alert) identifying common compliance issues related to Rule 206(4)-7 (the...more

Eversheds Sutherland (US) LLP

The DOJ issues its first FCPA advisory opinion after six years of silence

On August 14, 2020, the US Department of Justice (the DOJ) issued its first Foreign Corrupt Practices Act (FCPA) Opinion Procedure Release in six years, which relayed that it did not intend to pursue an enforcement action...more

Perkins Coie

Rare DOJ Opinion Offers Anti-Bribery Lessons for Transactions Involving Foreign Government-Owned Assets

Perkins Coie on

The U.S. Department of Justice (DOJ) has issued an opinion letter (catalogued as FCPA Opinion No. 20-01) stating that it does not intend to take enforcement action under the Foreign Corrupt Practices Act (FCPA) against a...more

Akin Gump Strauss Hauer & Feld LLP

2015-16 Compliance Developments & Calendar for Private Fund Advisers

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

Perkins Coie

SEC’s Increased Cybersecurity Enforcement and How to Reduce Your Risks

Perkins Coie on

The SEC announced last week that an investment adviser had agreed to settle charges that it failed to take required steps to protect against and respond effectively to a cybersecurity breach. The action comes on the heels of...more

Manatt, Phelps & Phillips, LLP

Corporate Investigations & White Collar Defense - September 2015

No Dog Days of August for the SEC—A Recap of a Busy Month - Why it matters: Who says there is a government slowdown in August? Not for the SEC. August 2015 turned out to be very busy indeed for the agency, which...more

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