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Thomas Fox - Compliance Evangelist

Data Driven Compliance: Understanding the ECCTA and Its Impact with Jonathan Armstrong

Welcome to Season 2 of the award-winning Data Driven Compliance. In this new season, we will look at the new Failure to Prevent Fraud offense. Join host Tom Fox as we explore this new law and how to comply with it through the...more

Walkers

Updated Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation Financing in the...

Walkers on

Following industry consultation, on 30 August 2023 the Cayman Islands Monetary Authority ("CIMA") issued updated Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation...more

Seward & Kissel LLP

SEC Charges FinTech Investment Adviser with First Violation of the Marketing Rule and Additional Compliance Violations

Seward & Kissel LLP on

Recently, the U.S. Securities and Exchange Commission (the “SEC”) announced charges against an investment adviser (the “Adviser”) for using hypothetical performance metrics in advertisements that were misleading pursuant to...more

Ankura

Failure to Prevent Fraud: Reasonable Procedures and Preparing Your Organization for the New Offense

Ankura on

An amendment to the Economic Crime and Corporate Transparency Bill (the Bill) has brought in the offense of failure to prevent fraud (Offense). Under the new Offense, an organization will be liable where a specified fraud...more

Akin Gump Strauss Hauer & Feld LLP

Fee Calculation Settlement Presents Broader Liability Concerns for Private Fund Managers

A recent enforcement action against two affiliated wealth management businesses raises concerns over whether and how other registered investment advisers will be subject to sanctions for issues that arise in the ordinary...more

Moore & Van Allen PLLC

The Devil Really is in the Details: The SEC Proposed Rule on Cybersecurity Risk Management for Investment Advisors, Registered...

Late last month the Securities and Exchange Commission (“SEC”) charged JP Morgan, UBS and Trade Station with violations of Regulation S-ID based on a range of  inadequacies in their identity theft red flag policies and...more

Burr & Forman

SEC Proposes Cybersecurity Rule for Advisers, Investment Companies

Burr & Forman on

On February 9, the SEC proposed new cybersecurity risk management regulations for investment advisers, registered investment companies (funds), and business development companies....more

Troutman Pepper Locke

SEC Focused on Enforcement in the Crowdfunding Space

Troutman Pepper Locke on

Following last year’s drastic increase in the annual limits permitted for crowdfunding campaigns, the Securities and Exchange Commission (SEC) has increased its focus on the regulation of crowdfunding, particularly for...more

Jones Day

SEC Adopts Updates to Proxy Voting Advice Regime

Jones Day on

The Situation: On July 22, 2020, the U.S. Securities and Exchange Commission ("SEC") adopted final rule amendments to regulate proxy voting advice as part of its emphasis on modernizing the proxy process. The final SEC...more

Faegre Drinker Biddle & Reath LLP

Recent FinCEN Advisory Details Dramatic Increase in Frequency and Severity of Business Email Compromise Fraud Schemes

On July 16, 2019, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued an “Updated Advisory on Email Compromise Fraud Schemes Targeting Vulnerable Business Processes” (the “Advisory”). The...more

Proskauer Rose LLP

SEC Issues Updated Guidance on Public Company Cybersecurity Disclosures

Proskauer Rose LLP on

On February 21, 2018, the Securities and Exchange Commission (SEC) issued an interpretive Commission Statement and Guidance on Public Company Cybersecurity Disclosures (the "Guidance") to assist public companies in meeting...more

Bracewell LLP

A Cyber Incident Moves Pretty Fast, If You Aren't Ready To Respond, You Might Blow It

Bracewell LLP on

The Securities and Exchange Commission (SEC) expanded its warnings to public companies that generic disclosures identifying cybersecurity risk factors may be insufficient. Rather, the SEC seems to expect companies to conduct...more

Holland & Knight LLP

U.S. Securities and Exchange Commission Updates Cybersecurity Disclosure Guidance - Agency Continues to Prioritize Cybersecurity...

Holland & Knight LLP on

• The U.S. Securities and Exchange Commission (SEC) released, on Feb. 21, 2018, updated guidance regarding public company cybersecurity disclosures. The guidance updates the Commission's 2011 non-binding guidance and...more

White and Williams LLP

SEC Updated Guidance on Cyber Disclosure by Publicly Traded Companies in a Digitally-Connected World

White and Williams LLP on

...The Securities and Exchange Commission (the “Commission”) Wednesday announced updated cybersecurity guidance for public companies. This guidance reinforces the Division of Corporation Finance guidance issued in October...more

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