Two SEC enforcement actions from earlier this month, each including charges against a firm’s Chief Compliance Officer in their personal capacity, underscore the importance of maintaining accurate records and upholding...more
8/1/2025
/ Books & Records ,
Chief Compliance Officers ,
Enforcement Actions ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Misleading Statements ,
Penalties ,
Personal Liability ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Regulatory Oversight ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC)
On July 21, 2025, the Department of the Treasury announced a two-year postponement of the much-anticipated anti-money laundering (AML) rule, adopted by Treasury’s Financial Crimes Enforcement Network (FinCEN) in 2024,...more
7/23/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Compliance ,
Customer Identification Program (CIP) ,
Final Rules ,
FinCEN ,
Investment Adviser ,
Regulatory Requirements ,
Rulemaking Process ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
Motivated by a rapidly evolving geopolitical climate, governments around the globe have increasingly scrutinized and intervened in transactions under foreign direct investment (FDI) screening regimes in recent years. Rising...more
On June 11, 2025, the Securities and Exchange Commission (“SEC”) voted to extend the compliance date for the most recently adopted amendments to Form PF by approximately four months, to October 1, 2025....more
Confession: writing this in May 2025, we cannot predict with confidence what the rest of 2025 will bring. The year has already seen four months of change and upheaval – political, regulatory, and economic. The new US...more
5/1/2025
/ Compliance ,
Department of Justice (DOJ) ,
Enforcement ,
Environmental Social & Governance (ESG) ,
Foreign Corrupt Practices Act (FCPA) ,
Investment Funds ,
Portfolio Companies ,
Private Equity ,
Private Funds ,
Regulatory Requirements ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
Markets remain exceptionally volatile following the announcement of the U.S. “Liberation Day” tariffs and retaliatory measures from other countries. While the ultimate path of policy remains uncertain, recent developments are...more
4/11/2025
/ Disclosure Requirements ,
Fund Managers ,
Investment ,
Investment Advisers Act of 1940 ,
Investors ,
Liquidity ,
Market Volatility ,
Portfolio Companies ,
Private Funds ,
Regulatory Requirements ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Tariffs ,
Valuation
On January 29, 2025, the Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (together, the “Agencies”) jointly announced that the compliance date for the new Form PF would be extended by three...more
1/31/2025
/ CFTC ,
Compliance ,
Financial Regulatory Reform ,
Form PF ,
Hedge Funds ,
Investment Adviser ,
New Amendments ,
Private Funds ,
Regulatory Requirements ,
Reporting Requirements ,
Rulemaking Process ,
Securities and Exchange Commission (SEC)