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Registration Enforcement Actions

Wiley Rein LLP

FARA 2021 Year in Review

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The Foreign Agents Registration Act (FARA) continued to make headlines in 2021 as enforcement and modernization of the law remained a U.S. Department of Justice (DOJ) priority. DOJ maintained its focus on enforcement,...more

Fox Rothschild LLP

Leaving Is The Hardest Part Especially If You Want To Re-Enter The Securities Industry

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We were recently reminded of how difficult it is to re-register for a position in the securities industry after being barred. See https://www.sec.gov/litigation/admin/2021/ia-5682.pdf. On February 9, 2021, the United...more

Proskauer - The Capital Commitment

SEC Announces New Approach to Disqualification Waivers

On July 3, 2019, SEC Chairman Jay Clayton issued a “Statement Regarding Offers of Settlement” (the “Statement”), announcing important changes to how the SEC will consider future requests for waivers from disqualifications in...more

Dorsey & Whitney LLP

Oppenheimer Settles with SEC, FinCEN

Dorsey & Whitney LLP on

Oppenheimer & Co., Inc. settled an action with the SEC centered on violations of the broker registration provisions, a failure to file suspicious activity reports or SARS and the sale of unregistered penny stock shares. The...more

Carlton Fields

Private Equity: The Next Wave of SEC Enforcement Actions?

Carlton Fields on

Ever since the Dodd-Frank Wall Street Reform and Consumer Protection Act required many investment advisers to private equity funds to register with the SEC for the first time, fund managers knew that additional scrutiny might...more

Goodwin

SEC Integrates Two Exempt Reporting Advisers to Determine Advisers Act Registration Status

Goodwin on

The SEC settled public administrative proceedings against TL Ventures Inc., a venture capital fund adviser (the “VC Fund Adviser”) and Penn Mezzanine Partners Management, L.P. (the “Private Fund Adviser” and with the VC Fund...more

Skadden, Arps, Slate, Meagher & Flom LLP

"SEC Issues Fine in Pay-to-Play Rule and Registration Requirement Violation Case"

On June 20, 2014, the Securities and Exchange Commission ("SEC") censured and fined investment adviser TL Ventures Inc. for violating the SEC's pay-to-play rule, Rule 206(4)-5 (the "Rule"), and failing to properly register...more

Dorsey & Whitney LLP

SEC’s First Advisers Act Pay-To-Play Action

Dorsey & Whitney LLP on

The Commission brought its first pay-to-play action involving political campaign contributions under the Investment Advisers Act. The proceeding is predicated on the integration of two firms which claimed to be exempt from...more

Ballard Spahr LLP

New CFPB Enforcement Action Involving Alleged ILSA Violations

Ballard Spahr LLP on

As we reported earlier this year, the CFPB was actively investigating a company called 3D Resorts-Bluegrass, LLC for possible violations of the Interstate Land Sales Full Disclosure Act (ILSA)....more

Brooks Pierce

SEC Charges Indian Firms with Acting as Unregistered Broker-Dealers

Brooks Pierce on

On November 27th, the SEC charged four Indian financial services firms with acting as unregistered broker-dealers in the United States....more

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