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Fund Managers Penalties

Lowenstein Sandler LLP

OFAC Imposes Largest-Ever Penalty on Nonbank Financial Institution for Egregious and Sustained Sanctions Violations—a $216M...

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a historic $215,988,868 civil monetary penalty against GVA Capital Ltd. (GVA), a venture-capital firm registered in the Cayman Islands...more

Morgan Lewis

OFAC Action Shows Risk of Not Recognizing That ‘Property Interests’ Include ‘Any Interest Whatsoever’

Morgan Lewis on

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) fined GVA Capital Ltd. $215 million, primarily for violating the Ukraine/Russia-related sanctions regulations, when GVA mistakenly concluded that it...more

Proskauer - Regulatory & Compliance

EU Regulators Take Different Enforcement Paths for ESMA ESG Fund Name Guidelines

European regulators have taken different routes as to how they plan to enforce the European Securities and Markets Authority’s (“ESMA”) guidelines (the “Guidelines”) with respect to the use of sustainability‑related terms in...more

Foley & Lardner LLP

SEC Settlement Highlights Importance of Proper Disclosure Requirements for Private Fund Managers

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On January 10, 2025, the Securities and Exchange Commission (SEC) settled charges against two fund managers (collectively the “Fund Managers”) and their sole owner, chief executive office, chief compliance office, and founder...more

Proskauer - The Capital Commitment

2022 SEC Enforcement Results – Takeaways for Fund Managers

Yesterday the SEC’s Division of Enforcement announced its Enforcement Results for Fiscal Year 2022, and there are a few key takeaways for fund managers. The Commission brought 760 total enforcement actions in FY 2022,...more

Jackson Walker

New FINRA Capital Acquisition Broker Rules May Offer Limited Relief to Private Investment Fund Advisers

Jackson Walker on

The U.S. Securities and Exchange Commission (“SEC”) recently approved a Financial Industry Regulatory Authority (“FINRA”) proposal to adopt a new regime for the regulation of electing broker-dealer firms that meet the...more

Broker-Dealer Compliance + Regulation

SEC Charges Private Fund Administrator with “Gatekeeper Failures”

Add fund administrators to the list of service providers the SEC expects to act as “gatekeepers.” In two separate settled actions last week, the SEC found that a private fund administrator “caused” the managers’ unregistered...more

Goodwin

Commerce Department Survey of Financial Services Transactions with Foreign Persons Due November 1, 2015

Goodwin on

The Commerce Department’s BE-180 Survey of Financial Services Transactions is a mandatory benchmark survey conducted every five years and administered by the Bureau of Economic Analysis (the “BEA”). Reports are required by...more

Latham & Watkins LLP

PE Firms: Prepare for the BEA’s Upcoming BE-180 Survey

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Private equity firms may be subject to new mandatory BEA reporting requirements with respect to their cross-border financial services transactions. The Bureau of Economic Analysis (BEA) of the US Department of Commerce...more

Troutman Pepper

The EU’s Alternative Investment Fund Managers Directive: Marketing Impact On Non-European Fund Managers

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Alternative investment fund managers based outside the European Economic Area (EEA) who wish to market their alternative investment funds (AIFs) to European investors are rightly concerned about additional restrictions and...more

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