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Compliance Private Funds Exempt Reporting Advisers (ERAs)

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Procopio, Cory, Hargreaves & Savitch LLP

When Must Private Fund Managers File as an Exempt Reporting Adviser in California?

Some private fund managers in California face potentially dire consequences if they fail to properly register with the state and the U.S. Securities and Exchange Commission (SEC). Failing to adhere to relevant securities laws...more

DLA Piper

National Security Risks Headline New AML Requirements for Investment Advisers – and More to Come?

DLA Piper on

Last week, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a widely anticipated final rule to police the estimated $125 trillion-plus investment adviser market. The new rule extends...more

Seward & Kissel LLP

FinCEN Proposes AML Requirements for Certain Investment Advisers

Seward & Kissel LLP on

On February 13, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (the “Proposed Rule”) that would subject registered investment advisers (“RIAs”) and...more

Mintz

Compliance Dates Are Set: A Roadmap for Private Fund Advisers to Start Preparing for the SEC’s New Rules for Private Fund Advisers

Mintz on

The US Securities and Exchange Commission (“SEC”) recently finalized sweeping new rules for private fund advisers (the “PFA Rules”) under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). The PFA Rules...more

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