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False Claims Act Insights - How Payment Suspensions Can Impact FCA Litigation
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State AG Pulse | Massive Google Settlement Shows AGs Serious About Privacy
Episode 369 -- Stepping Into the Enforcement Spotlight -- Customs and Border Patrol and Import Enforcement
10 For 10: Top Compliance Stories For the Week Ending May 17, 2025
Daily Compliance News: May 16, 2025, The Ethics Nightmare Edition
State AGs Unite: New Privacy Task Force Signals Shift in Regulatory Power Dynamics — The Consumer Finance Podcast
Daily Compliance News: May 15, 2025, The Downfall in Davos Edition
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All Things Investigations: Task Force Strategies - Addressing New Government Priorities
Daily Compliance News: May 12, 2025, The Corruption in the Broad Daylight Edition
10 For 10: Top Compliance Stories For the Week Ending May 10, 2025
Daily Compliance News: May 9, 2025, The Bring Out Your Dead Pardon Edition
Everything Compliance: Episode 153, The CW 25 Edition
ADA Compliance for Medical and Dental Practices: Responding to Inquiries and Investigations
Consumer Finance Monitor Podcast Episode: The Impact of the Election on the FTC
Daily Compliance News: May 8, 2025, The $1MM for a Pardon Edition
Builder of Investment Models Deviates From Blueprints Employee’s Rogue Remodeling Costs Builder Plenty - The SEC’s recent order instituting administrative and cease-and-desist proceedings (OIP) against registered...more
The SEC’s recent order instituting administrative and cease-and-desist proceedings (OIP) against registered investment advisers Two Sigma Investments LP and Two Sigma Advisers LP illustrates significant risks for investment...more
Registered investment advisers have until January 1, 2026, to comply with the anti-money laundering (AML) compliance provisions of the Bank Secrecy Act (BSA). However, the SEC has recently charged two investment advisers with...more
On April 7, 2024, the United States District Court for the District of Connecticut approved the Securities and Exchange Commission’s request to dismiss its action against a hedge fund manager for the manager’s alleged failure...more
SEC Clarifies Marketing Rule, Warms up to Crypto and Private Placements under 506(c), and Backs off Form SHO; Latest Lessons from EXAMS: Duty of Care and Risk Identification Failures - Welcome to our February and March 2025...more
There has been a lot of conjecture that the SEC may become friendlier to registrants because of the new administration. Given the SEC’s mandate to protect the investing public, however, we do not expect SEC examiners to...more
On January 16, 2025, the SEC announced the settlement of administrative proceedings brought against a hedge fund manager that used algorithmic investment models to provide investment advice to its private fund and separately...more
Web3 represents the next evolution of the internet, characterized by decentralized networks and blockchain technology, enabling user-centric platforms and applications with enhanced security and data ownership. Digital...more
Quick Take: Indicative of a recent SEC focus on bank deposit sweep programs (BDSPs) offered to advisory clients through broker-dealers, the SEC recently settled charges against three dually registered investment advisers and...more
The US Securities and Exchange Commission (SEC) brought a number of significant enforcement proceedings against investment advisers and broker-dealers in FY 2024 and during the first quarter of FY 2025. If history serves as a...more
Hedge clauses are provisions in investment advisory agreements that aim to limit an adviser’s liability for certain actions or outcomes. The U.S. Securities and Exchange Commission (the “SEC”) has expressed the position that...more
2024 was a year of meaningful regulatory change for asset managers globally. The regulatory activity was wide ranging and without a particular unifying theme. In fact, the wide, and in cases diverging focuses of key global...more
On February 6, 2025, the SEC announced that it was providing a temporary exemption from compliance with Rule 13f-2 under the Securities Exchange Act of 1934 (the “Exchange Act”), which establishes a mandatory short reporting...more
The new year always marks the start of a busy regulatory filing season for registered investment advisers, including investment advisers that file Form PF (“Form PF Filers”). This year could be especially challenging since,...more
In 2024, private funds continued to be a major focus for the US Securities and Exchange Commission (SEC), with an active docket of enforcement cases and rulemaking efforts. Although we expect 2025 to include a continued...more
Once upon a time, in 1994, when I was a young lawyer in the SEC’s Division of Investment Management (Division), Office of Chief Counsel, we received a request to modify a previously granted but totally impractical no-action...more
In this issue of our monthly Securities Enforcement Roundup, we highlight top securities enforcement developments and cases from December 2024. In December 2024: President-elect Trump nominated former SEC Commissioner Paul...more
In a significant development for the investment management industry, a large adviser agreed to pay a hefty $17.5 million civil penalty to settle charges with the SEC over misleading statements about its Environmental, Social,...more
The SEC’s September 17, 2024, actions signal its commitment to penalize non-compliance, while encouraging market participants to self-report violations. On September 17, 2024, the US Securities and Exchange Commission...more
On September 17, 2024, the Securities and Exchange Commission announced cease-and-desist proceedings against eleven institutional investment managers for failure to file reports required by the Securities Exchange Act of...more
On April 12, 2024, the U.S. Securities and Exchange Commission imposed fines and other sanctions on five registered investment advisers (RIAs) for violations of the Investment Adviser Marketing Rule (Rule 206(4)-1), which has...more
On April 12, 2024, the U.S. Securities and Exchange Commission (the “SEC”) announced settled charges against five registered investment advisers for violations of Rule 206(4)-1 (the “Marketing Rule”) under the Investment...more
On April 3, 2024, the US Securities and Exchange Commission (“SEC”) brought its first enforcement action against a “stand-alone” SEC registered investment adviser (“RIA”) for violations of, among others, Section 204 of and...more
On March 18, 2024 the US Securities and Exchange Commission (“SEC” or the “Commission”) announced that it had settled charges in separate actions against two investment advisers, Delphia (USA) Inc. (“Delphia”) and Global...more
On April 3, 2024, the U.S. Securities and Exchange Commission (SEC) announced its first enforcement action against a registered investment adviser (RIA) with no ties to a broker-dealer regarding so-called “off-channel”...more