Compliance into the Weeds: The Dark Side of AI in Employee Training
What to Do When Leadership Doesn’t Take Compliance Seriously
Compliance Tip of the Day - The ROI of Compliance
Moving Beyond the Usual Helpline Data
Avoiding a Bored Board
Compliance Tip of the Day: Compliance Responses to Design Intelligence
Compliance Tip of the Day: Avoiding CCO Liability
#Risk New York Speaker Series: Exploring AI Risks in Compliance with Gwen Hassan
Everything Compliance: Episode 155, To Tesla and Beyond Edition
Great Women in Compliance: Culture. Data. Ethics with Hui Chen
Compliance Amidst a Global Consensus Breakdown
Great Women in Compliance – Compliance is the Floor, Ethics is the Ceiling with Ellen Hunt
Innovation in Compliance: Innovative Approaches to Compliance and Training with Catherine Choe
FCPA Compliance Report: Upping Your Game in Compliance
Compliance Tip of the Day: Empowering Middle Managers to Drive Compliance Transformation
Creativity and Compliance: From Compliance Enforcers to Trusted Advisors: The Path Forward
Compliance Tip of the Day: Middle Managers as the Eyes and Ears of Compliance
Great Women in Compliance: Exploring the Future of Compliance - Key Takeaways from Compliance Week 2025
Mistakes Lawyers Should Avoid When Moving into Compliance
Innovation in Compliance: Exploring the Fractional COO Model with La Tonya Roberts
As discussed in our prior article, it's important to have a well-built foundation for your compliance program. But creating the program is just the start of the journey. Compliance is a journey requiring adaptation,...more
Our Investment Funds Group reviews the implications of a Commodity Futures Trading Commission (CFTC) policy targeting chief compliance officers (CCOs) as individuals if their companies’ compliance programs fail....more
The compliance date for the SEC’s new investment adviser Marketing Rule is November 4, 2022, allowing just over a month for an investment adviser to finalize its implementation process to comply with the Rule, which applies...more
Environmental, Social, and Governance (ESG) risks cannot be effectively managed as an isolated function within a company, nor are they issues only for publicly traded companies. ESG is front and center for organizations of...more
DISCUSSION OVERVIEW - - Duty to Establish a Compliance Program - Chief Compliance Officer (“CCO”) - Written Policies and Procedures - Annual Review Process - SEC Exams and Enforcement - Code of Ethics ...more
Adoption in 1962 - The SEC has regulated custodial practices of investment advisers since 1962, when it first adopted rule 206(4)-2 (the “Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”) under...more
The SEC staff now says that mutual fund directors can rely on chief compliance officer certifications in determining compliance with board procedures required by SEC exemptive Rules 10f-3, 17a-7, and 17e-1 under the...more
On October 12, 2018, the staff of the SEC’s Division of Investment Management issued a no-action letter to the Independent Directors Council (“IDC”) agreeing that the staff will not recommend enforcement if, in lieu of making...more
As we start the New Year, we would like to remind our clients of certain regulatory developments and upcoming deadlines for Q1 2018. New Form ADV - The new Form ADV takes a deeper dive by requiring additional...more
David I. Osunkwo was a principal at Strategic Consulting Advisors, LLC, or SC Consulting. SC Consulting offered compliance consulting and CCO services to two SEC registered investment adviser firms under common control, Aegis...more
The SEC’s Office of Compliance Inspections and Examinations, or OCIE, recently issued a risk alert titled “Examinations of Advisers and Funds That Outsource Their Chief Compliance Officers.” According to the alert, OCIE...more
Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more
According to the SEC’s most recent financial report, as of August 2014, SEC-registered investment advisers managed $62.3 trillion in assets. Not surprisingly, investment advisers attract a great deal of attention from the...more
SEC Commissioner Daniel Gallagher, in a speech on June 25, 2015, said that a perceived trend by the SEC toward “strict liability” for chief compliance officers (CCOs) is “sending a troubling message.” The statement...more
In This Issue: - SEC Proposes Changes to Reporting and Disclosure Obligations for Investment Companies and Advisers - SEC Charges Hedge Fund Executives and External Auditor for Improper Disclosure of Expense...more