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Compliance Policies and Procedures Material Nonpublic Information

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 -
Snell & Wilmer

SEC Reporting Update - December 2024

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Insider Trading Policies. As previously discussed in our Winter 2022-2023 Corporate Communicator, the Securities and Exchange Commission (“SEC”) adopted final rules in December 2022 relating to insider trading policy...more

WilmerHale

SEC Enforcement Actions Reflect Expanding Focus on Advisers’ Policies and Procedures to Prevent Misuse of Material Nonpublic...

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The Securities and Exchange Commission (SEC) recently brought settled enforcement actions against two registered investment advisers for failing to establish, maintain, and enforce written policies and procedures reasonably...more

WilmerHale

SEC Sanctions CLO Manager for Inadequate Polices to Prevent Nonpublic Information Misuse

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On August 26, 2024, the Securities and Exchange Commission (SEC) announced an order against a registered investment adviser, Sound Point Capital Management, LP, for its failure to “establish, maintain, and enforce written...more

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