False Claims Act - When Does Embellishing Become Fraud?
What is Fraud and How to Defend Against the Claim
Three recent enforcement actions highlight the risks of failing to adhere to representations made to investors regarding ESG and biblically responsible investing strategies....more
How statements in both traditional and new media outlets may catch the SEC’s attention. From music moguls and sports icons promoting cryptocurrencies and digital tokens,1 to reality television stars bringing down the price...more
I. Advertising Rule Compliance Issues - On September 14, 2017, the staff of the SEC's Office of Compliance Inspections and Examinations (OCIE) issued a National Examination Program Risk Alert on the most frequent advertising...more
David I. Osunkwo was a principal at Strategic Consulting Advisors, LLC, or SC Consulting. SC Consulting offered compliance consulting and CCO services to two SEC registered investment adviser firms under common control, Aegis...more
The SEC recently instituted proceedings against a registered investment adviser and its founder, CEO and majority shareholder for allegedly making material misstatements and omissions regarding the amount of assets...more