News & Analysis as of

Enforcement Actions Investment Adviser Financial Markets

Bradley Arant Boult Cummings LLP

SEC Enforcement in the Second Quarter of 2025

In May 2025, we summarized the U.S. Securities and Exchange Commission’s (SEC) Division of Enforcement activity during the first quarter of the new presidential administration. With the second quarter now concluded, and Paul...more

DLA Piper

SEC Enforcement Actions Highlight Anti-Money Laundering Reporting Focus for Financial Gatekeepers

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The Securities and Exchange Commission (SEC) announced on November 22, 2024, that three broker-dealers have agreed to settle charges for filing suspicious activity reports (SARs) that failed to include important, required...more

Troutman Pepper Locke

SEC 2024 Enforcement Results: A Decline in Total Enforcement, but a Record-Breaking Recovery of Financial Remedies

Troutman Pepper Locke on

On November 22, the Securities and Exchange Commission (SEC) announced its enforcement results for fiscal year (FY) 2024. As compared to FY 2023, the Division of Enforcement (the division) reported a 26% decline in the total...more

Ballard Spahr LLP

Are Whistleblower Protection Violations the New SEC Sweep?

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The Securities and Exchange Commission (SEC) continues to investigate companies for including language in their employment and separation agreements or retail client settlement agreements that potentially discourages...more

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for July 2024

SEC Loses in ALJ Case, DOL’s Latest Fiduciary Rule Put on Hold, and SEC Reconsiders AI and Custody Rule Proposals - Welcome to our July Regulatory Roundup, where we provide a quick look at the latest regulatory developments....more

Jenner & Block

Client Alert: Court Adopts SEC's New Unregistered Dealer Theory, Creates Risk of Disgorgement and Penalties for Anyone Trading...

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A broad array of financial market participants—mutual funds, private funds, insurers, pension funds, family offices, individuals, and more—may be at risk after the Securities and Exchange Commission (SEC) secured summary...more

A&O Shearman

SEC Enforcement In FY 2021 Included Significant Actions In Traditional And Emerging Areas And Over $1 Billion In Whistleblower...

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On November 18, the U.S. Securities and Exchange Commission (“SEC”) announced its enforcement results for the 2021 fiscal year, which ended on September 30, 2021.  The SEC reported that it filed 434 new enforcement actions in...more

A&O Shearman

Consulting Firm Settles Allegations That It Had Inadequate Procedures For Handling Of MNPI Between Units

A&O Shearman on

On November 19, 2021, the Securities and Exchange Commission (“SEC”) announced that an affiliate of McKinsey & Company (“McKinsey”), McKinsey Investment Office Partners, Inc. (“MIO”), had agreed to pay an $18 million penalty...more

A&O Shearman

Revised Global Principles on Outsourcing for Regulated Participants in the Securities Markets

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The International Organization of Securities Commissions has published an updated Principles on Outsourcing for regulated market participants in the securities markets.  The updated Principles are based on IOSCO’s 2005...more

Proskauer - The Capital Commitment

Valuation in Times of Market Disruption

Valuation practices will continue to be the subject of disputes. Particularly in times of economic disruption and market volatility, buyers and sellers are more likely to have substantial differences of opinions on valuation,...more

Herbert Smith Freehills Kramer

Funds Talk: August 2017 - SEC Settles With Investment Adviser in Connection With a Conflict of Interest in a Client Transaction

On July 6, the Securities and Exchange Commission (SEC) reached a settlement with respondent Paramount Group Real Estate Advisor LLC (Respondent) regarding certain alleged violations of the Investment Advisers Act of 1940, as...more

BakerHostetler

2016 Year-End Securities Litigation and Enforcement Highlights

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Welcome to the 2016 Year-End Report from the BakerHostetler Securities Litigation and Regulatory Enforcement Practice Team. The purpose of this Report is to provide a periodic survey, apart from our team Executive...more

Ballard Spahr LLP

Investment Management Update

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SEC Issues Guidance on Mutual Fund Fee Structure - The Securities and Exchange Commission’s (SEC) Division of Investment Management recently issued a guidance update addressing disclosure issues and certain procedural...more

Proskauer - Corporate Defense and Disputes

SEC Staff Announces 2017 OCIE Examination Priorities

On January 12, 2017, the staff of the Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) released its annual announcement on examination priorities in the coming calendar...more

Ballard Spahr LLP

Investment Management Update

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IRS Issues Proposed Regulations Providing Guidance On The Tax Qualification Of Mutual Funds - On September 27, 2016, the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) that provide...more

Proskauer - The Capital Commitment

SEC Announces Record Number of Investment Adviser Cases for FY 2016

The Securities and Exchange Commission today announced its enforcement results for fiscal year 2016, reaching new highs in the number of actions filed and money ordered forfeited through disgorgement and penalties. The SEC...more

Ballard Spahr LLP

Investment Management Update

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The Securities and Exchange Commission Adopts Amendments to Form ADV and Investment Adviser Act Rules - The Securities and Exchange Commission (SEC) adopted amendments to Form ADV and Investment Advisers Act of 1940...more

Burr & Forman

Tennessee Securities Division Ramps Up Enforcement

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The Securities Division of Tennessee’s Department of Commerce and Industry has increased its enforcement activity during 2016. The recent actions include: Final Administrative Orders: Clifton Alexander and HugeROI.com...more

Troutman Pepper

The SEC Releases the First Distribution-In-Guise Enforcement Action Concerning Fund Assets Used to Pay For Marketing and...

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The SEC’s order provides significant guidance on how the SEC staff will scrutinize the propriety of payments made pursuant to commonly occurring agreements between mutual funds and their service providers and with respect to...more

BakerHostetler

2015 Mid-Year Securities Litigation and Enforcement Highlights

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Welcome to the 2015 Mid-Year Report from the BakerHostetler Securities Litigation and Regulatory Enforcement Practice Team. The purpose is to provide a periodic survey, apart from our team Executive Alerts, on matters we...more

Burr & Forman

SEC Enforcement Actions Against IA CCO’s: Aguilar & White Respond to Gallagher

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In mid-June, SEC Commissioner Gallagher issued a strongly-worded public dissent from two enforcement actions against investment-adviser CCOs, accusing the Commission of “cutting off its nose to spite its face” by punishing...more

Carlton Fields

Can “Bad Actors” Wave Goodbye to SEC Waivers?

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The SEC has been thinking harder before waiving automatic disqualifications that the federal securities laws and regulations impose on so-called "bad actors." Without such waivers, companies may be barred from, among...more

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