SEC v. Nagler is the second enforcement action charging an investment adviser with undisclosed conflicts of interest since Chair Paul Atkins began his tenure on April 21, 2025. The Securities and Exchange Commission (SEC)...more
Judge Engelmayer’s 107-page dismissal of most of the U.S. Securities and Exchange Commission (SEC)’s claims against SolarWinds provides valuable guidance, and some comfort, for public companies and Chief Information Security...more
8/19/2024
/ Chief Information Security Officer (CISO) ,
Corporate Counsel ,
Cyber Attacks ,
Cybersecurity ,
Disclosure Requirements ,
Fraud ,
Internal Controls ,
Misrepresentation ,
Negligence ,
Ransomware ,
Scienter ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
SolarWinds
Last month, the United Kingdom Financial Conduct Authority (FCA) announced that it is considering new procedures under which it would publicly identify firms that are under investigation as soon as the investigation has been...more
4/1/2024
/ Cross-Border ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Enforcement ,
Financial Conduct Authority (FCA) ,
FSMA ,
Investigations ,
Notice Requirements ,
Securities and Exchange Commission (SEC) ,
UK ,
Willful Misconduct
Key Takeaways -
With the SolarWinds enforcement action, the SEC continues to ratchet up its enforcement against companies that fail to properly disclose their cybersecurity incidents and risks. By naming the SolarWinds CISO...more
11/22/2023
/ Chief Information Security Officer (CISO) ,
Cyber Attacks ,
Cyber Incident Reporting ,
Cybersecurity ,
Disclosure Requirements ,
Enforcement Actions ,
Fraud ,
Incident Response Plans ,
Popular ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
SolarWinds
Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents*
I. Introduction -
The SEC-registered investment adviser (“adviser”) population is large and diverse, ranging from global asset managers...more
9/12/2023
/ Audits ,
Brokerage Accounts ,
Business Operations ,
Compliance ,
Cybersecurity ,
Disclosure Requirements ,
Ethics ,
Financial Records ,
Insider Trading ,
Internal Controls ,
Investment Adviser ,
Marketing ,
Policies and Procedures ,
Risk Alert ,
Risk Management ,
Securities ,
Securities and Exchange Commission (SEC) ,
Trading Platforms ,
Valuation
Key Points -
On February 3, 2023, Activision Blizzard settled charges with the SEC, agreeing to pay $35 million to resolve novel claims that the company failed to maintain adequate disclosure controls to track workplace...more
On July 26, 2021, 21 investment advisers entered into settlements with the Securities and Exchange Commission to resolve charges that they failed to timely file and deliver their relationship summaries on Form CRS. Penalties...more
On July 21, 2021, the Securities and Exchange Commission’s Division of Examinations issued a Risk Alert on cross trades and principal transactions.1 The Risk Alert’s guidance and warnings were based on over 20 examinations of...more