On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date for certain investment advisers to implement anti-money...more
7/24/2025
/ AML/CFT ,
Anti-Money Laundering ,
BSA/AML ,
Compliance ,
Financial Crimes ,
FinCEN ,
Investment Adviser ,
Investment Management ,
Regulatory Requirements ,
Rulemaking Process ,
Suspicious Activity Reports (SARs)
In a Legal Alert issued before yesterday’s SEC Open Meeting, we posed questions relating to six things that our Investment Services team would be looking for. We now have answers to some of those questions....more
The US Securities and Exchange Commission (SEC) is holding an open meeting this Wednesday, August 23, to consider whether to adopt proposed rules under the Investment Advisers Act of 1940 that, if adopted as proposed, would...more
8/22/2023
/ Audits ,
Compliance ,
Disclosure Requirements ,
Fees ,
Financial Statements ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Policies and Procedures ,
Private Funds ,
Proposed Amendments ,
Proposed Rules ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC)
Now that the dust has settled on the SEC’s enforcement action against fifteen (15) broker-dealers and an investment adviser for violations of SEC recordkeeping rules applicable to the use of personal devices and off-channel...more
On January 28, 2014, the U.S. Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert entitled: Investment Adviser Due Diligence Processes for Selecting...more