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
After its fiscal year-end frenzy in September, the SEC relaxed slightly, with no new rule-making and fewer enforcement actions. So, I took a break last month and combined the October and November Roundups. (You’re welcome.)...more
11/27/2024
/ Asset Management ,
Compliance ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
Fiduciary Duty ,
Greenwashing ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Firms ,
Private Funds ,
Registered Investment Advisors ,
Regulation S-P ,
Regulatory Requirements ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Violations
Advisers Drafted by FinCEN for AML Duty, More Fines for E-Comm Retention Failures and a September Miracle, SEC Falls Back on Broken Windows Strategy, and a Refusal to Give Up on Private Fund Rules - FinCEN added to advisers’...more
10/1/2024
/ Anti-Money Laundering ,
Asset Management ,
Enforcement Actions ,
Exempt Reporting Advisers (ERAs) ,
FinCEN ,
Investment Adviser ,
Investors ,
Private Funds ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Settlement ,
Suspicious Activity Reports (SARs)
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
8/28/2024
/ Asset Management ,
Chief Compliance Officers ,
Compliance ,
Compliance Monitoring ,
Corporate Governance ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Portfolios ,
Policies and Procedures ,
Portfolio Managers ,
Regulatory Requirements ,
Risk Mitigation ,
Securities and Exchange Commission (SEC)