Compliance Amidst a Global Consensus Breakdown
Compliance Tip of the Day: Compliance Training Frequency
Compliance Tip of the Day: Design Objectives for Compliance Training
FCPA Compliance Report: The Power of Peer Support and Purpose Driven Leadership with Sarah Cole
Innovation in Compliance: Innovative Approaches to Compliance and Training with Catherine Choe
Compliance Tip of the Day: Multiplying the Influence of Compliance
Compliance tip of the Day: Communication Through Persuasion
Compliance Tip of the Day: Empowering Middle Managers to Drive Compliance Transformation
Compliance Tip of the Day: Middle Managers as the Eyes and Ears of Compliance
Compliance Tip of the Day – Role of Chatbots in Compliance
Beyond the Bylaws: The Medical Staff Show | The Role of Bylaws in Medical Staff Governance, Part II
The Presumption of Innocence Podcast: Episode 60 - Enforcement Priorities of the Second Trump Administration: Employee Retention Tax Credit
Compliance Tip Of the Day: Using AI to Transform Whistleblower Response
FCPA Compliance Report: Amanda Carty on a Due Diligence and Risk Management
FCPA Compliance Report: Kristy Grant-Hart on A 360° Review of the Future of Compliance
Great Women in Compliance: Creating Space to Speak Up: The Story Behind Psst.org
Work This Way: A Labor & Employment Law Podcast | Episode 43: How Employers Can Navigate White Collar Crime with Erica Barnes & Christian Dysart of Maynard Nexsen
The Presumption of Innocence Podcast: Episode 59 - Enforcement Priorities of the Second Trump Administration: DOJ Focus
Creativity and Compliance: Bringing Joy to Compliance: A Conversation with Virginia MacSuibhne
Beyond the Bylaws: The Medical Staff Show - The Role of Bylaws in Medical Staff Governance, Part I
Chief Compliance Officers face the challenge of running a comprehensive yet efficient compliance program that nimbly adapts to changing regulatory requirements and business practices. As compliance consultants, we see our...more
The US Securities and Exchange Commission (SEC) has approved a streamlined framework for co-investments involving certain closed-end funds and business development companies (together, Regulated Funds)....more
Many compliance officers live in hope that if they ramp up their persuasive skills, engage employees with spectacular training presentations, and provide succinct and prompt advice, they will receive the respect and...more
As we look back on the SEC’s actions in 2024, we wanted to share our thoughts on lessons learned that we believe will carry through to 2025....more
On January 10, 2025, the Securities and Exchange Commission (SEC) settled charges against two fund managers (collectively the “Fund Managers”) and their sole owner, chief executive office, chief compliance office, and founder...more
Who may be interested: Registered Investment Companies; Registered Investment Advisers; Compliance Officers - Quick Take: The SEC charged a hedge fund manager registered as an investment adviser (Adviser) with failing to...more
Investment advisers and others involved in the implementation of the new IA AML mandate have been alert to potential ramifications to the rule due to the upcoming change in administration. Upon review, K2 Integrity and...more
On December 12, 2024, the Securities and Exchange Commission (“SEC”) filed a litigated complaint (the “Complaint”) in United States District Court for the District of Connecticut against a hedge fund manager (the “Firm”)...more
Two weeks ago, this Blog wrote about an enforcement action involving an investment adviser’s former co-chief investment officer who had been charged with running a more than $600 million cherry-picking scheme (here). Today,...more
These days, artificial intelligence is everywhere we look, and the financial services industry is no different. As AI use increases, regulatory bodies are updating their rules and guidelines detailing how companies should and...more
As the end of 2024 approaches, it is crucial that all investment advisers—including registered investment advisers (RIAs) and exempt reporting advisers (ERAs)—complete end of the year regulatory and compliance tasks and...more
In addition to basic blocking and tackling, compliance officers often have the thankless job of performing the annual review of their compliance program required by Advisers Act Rule 206(4)-7....more
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
Who may be interested: Registered Investment Companies; Investment Advisers - Quick Take: The SEC recently settled charges against a registered investment adviser for violating the requirements of Rule 206(4)-1 of the...more
On November 8, 2024, the U.S. Securities and Exchange Commission (“SEC”) announced a settled enforcement action (the “SEC Order”) against Invesco Advisers, Inc. (“Invesco”), an investment advisory firm, for making misleading...more
In a two-part legal update, we will discuss key information SEC registrants should know going into the upcoming review cycle conducted by the Division of Examinations (the Division). This first update attempts to demystify...more
On August 28, the Financial Crimes Enforcement Network (FinCEN) issued a final rule establishing anti-money laundering and countering the financing of terrorism (AML/CFT) compliance obligations for US Securities and Exchange...more
On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...more
On October 21, 2024, the Division of Examinations (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC”) issued its annual examination priorities for fiscal year 2025. As with its 2024 examination...more
On August 26, 2024, it was not the first time the SEC settled charges with a Registered Investment Adviser (RIA) for willfully violating Section 204A of the Investment Advisers Act (204A) by failing to establish, maintain and...more
On September 9, the U.S. Securities and Exchange Commission (SEC) announced another series of settlements with registered investment advisers for violations of Rule 206(4)-1, as amended (Marketing Rule), under the Investment...more
Who may be interested: Registered Investment Advisers, Registered Investment Companies, Compliance Staff - Quick Take: The SEC recently announced a number of additional enforcement actions relating to recordkeeping...more
Who may be interested: Investment Advisers; Compliance Staff - Quick Take: The SEC announced that it had settled charges against a registered investment adviser (Adviser) for failing to establish, maintain, and enforce...more
On August 19, 2024, the U.S. Securities and Exchange Commission (SEC) settled with a registered investment adviser (Adviser),1 whereby the Adviser paid a $95,000 civil money penalty in addition to being censured for...more
Most compliance officers struggle to determine whether they are conducting enough testing to satisfy their obligations under the Advisers Act. In its release adopting Advisers Act Rule 206(4)-7, the SEC stated that an...more