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Investment Funds Internal Controls

Conyers

Regulatory & Risk Advisory Review: Cayman Islands – August to October 2023

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Welcome to the third instalment of our Cayman Islands Regulatory & Risk Advisory Review. As we cover in this issue, there have been a number of exciting developments, including the welcome news of the Financial Action Task...more

Goodwin

The FCA’s 2023/24 Priorities for UK Payments: Firms and Investors, Take Note

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On March 16, 2003, the UK Financial Conduct Authority (FCA) published its letter Portfolio Letter: FCA priorities for payments firms to the CEOs of UK Payment Institutions (PIs), Electronic Money Institutions (EMIs), and...more

Proskauer Rose LLP

Regulation of Custodial Practices Under the Investment Advisers Act of 1940 Rule 206(4)-2: September 2020

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A. Adoption in 1962 - The SEC has regulated custodial practices of investment advisers since 1962, when it first adopted rule 206(4)-2 (the “Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”) under...more

Pillsbury Winthrop Shaw Pittman LLP

Registration and Compliance Obligations are Reality for Private Funds in the Cayman Islands

New law imposes registration and compliance obligations on private funds that carry on business in or from the Cayman Islands. Absent an exemption, all private funds that carry on business in or from the Cayman Islands will...more

Hogan Lovells

U.S. Sanctions regulator outlines expectations for Global Sanctions Compliance: impact on Private Equity

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On 2 May 2019, the U.S. Treasury's Office of Foreign Assets Control ("OFAC"), the agency responsible for enforcing economic sanctions, published "A Framework for OFAC Compliance Commitments" (the "Framework") which outlines...more

Thomas Fox - Compliance Evangelist

Farewell to Dr. Z: A Guilty Plea and Two Indictments in 1MDB

In a three-count Indictment, another Goldman Sachs employee, Roger Ng, was charged with conspiracy to violate the FCPA and money-laundering. Ng was arrested in Singapore and will presumably be transported to the US to stand...more

The Volkov Law Group

Goldman Sachs and the 1MDB Criminal Prosecutions

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The 1Malaysia Development Berhad scandal (“1MDB scandal”) has been making headlines for the past few years. The turning point for US prosecutors was the cooperation of Malaysian law enforcement and the corruption allegations...more

Dorsey & Whitney LLP

Recent Enforcement Provides Guidance on Internal Controls and Disclosure for Quant Managers

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The recent enforcement action by the Securities and Exchange Commission (“SEC”) against Aegon USA Investment Management (“AUIM”) and three affiliated companies provides helpful guidance to investment advisers who employ...more

Dechert LLP

Financial Services Quarterly Report - First Quarter 2018: Hong Kong SFC Publishes Consultation Proposals on Public Fund...

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Following an initial “soft” consultation with industry participants and relevant stakeholders, the Securities and Futures Commission (SFC) launched a three-month consultation on proposed amendments to the Code on Unit Trusts...more

Akin Gump Strauss Hauer & Feld LLP

SFC Highlights Deficiencies in Asset Management Industry

• The SFC has identified nine common areas of non-compliance in managing funds and discretionary accounts. • The SFC urged licensed corporations to review their existing internal control procedures and operational...more

Dorsey & Whitney LLP

This Week In Securities Litigation

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The Newman personal benefit test in insider trading tipping cases is front and center this week as the Supreme Court agreed to consider the issue. The Court passed on the opportunity to consider the question when first...more

Troutman Pepper

Observation 3.0: Frequently Asked Questions and Answers on the Volcker Rule and the Implications for Foreign Banks Investing in...

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1. Question: What is the Volcker Rule, and when does it take effect? Answer: The Volcker Rule was enacted into law as section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank...more

Dorsey & Whitney LLP

This Week In Securities Litigation

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The Commission announced its largest whistleblower action this week – an award to a person overseas of over $30 million. The agency also filed a series of actions this week....more

Goodwin

SEC Settles Administrative Proceedings Against London-Based Hedge Fund Adviser and its Parent over Internal Control Failures and...

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The SEC settled public administrative proceeding against a London-based hedge fund adviser that is not registered with the SEC (the “Adviser”) and its U.S. based, publicly-traded parent (the “Parent”) with respect to internal...more

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