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Investment Adviser Securities and Exchange Commission (SEC) Regulatory Requirements

Proskauer Rose LLP

SEC Cites Falsified Compliance Records in Two Recent SEC Settlements with CCOs

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Two SEC enforcement actions from earlier this month, each including charges against a firm’s Chief Compliance Officer in their personal capacity, underscore the importance of maintaining accurate records and upholding...more

Latham & Watkins LLP

FinCEN Postpones New AML Rule for Investment Advisers

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On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule concerning the Anti-Money Laundering/Countering...more

Cooley LLP

FinCEN to Postpone Investment Adviser Anti-Money Laundering Rule

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On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to (1) postpone until January 1, 2028, the effective date of the final anti-money laundering rule...more

Lowenstein Sandler LLP

Bank Secrecy Act Postponed for Investment Advisers and Exempt Reporting Advisers

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On July 21, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone compliance with new regulatory requirements imposing certain anti-money laundering...more

DLA Piper

SEC Targets Investment Adviser Cherry-picking in Recent Enforcement Actions

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The US Securities and Exchange Commission (SEC) has sharpened its focus on “cherry-picking,” a practice in which investment advisers allocate profitable trades to favored accounts – sometimes their own – while assigning less...more

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

Eversheds Sutherland (US) LLP

Dual registrant regulatory roundup - July 2025

Welcome to the Regulatory Roundup. Each month, Eversheds Sutherland Investment Services attorneys review significant regulatory developments (including notable rulemakings and guidance from securities regulators) from the...more

Stinson LLP

SEC Withdraws Proposed Rules Affecting Investment Advisors, Funds and Broker-Dealers

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On June 12, 2025, the Securities and Exchange Commission (SEC) withdrew 14 outstanding proposed regulations issued during the Biden Administration. These withdrawals underscore a dramatic priority shift away from regulation...more

Lowenstein Sandler LLP

The BSA’s Expansion & How Investment Advisers Can Leverage Existing AML Compliance Programs in the Cayman Islands To Comply With...

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On Aug. 28, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the Final Rule) extending the scope of the Bank Secrecy Act (BSA) and its amendments by requiring certain...more

Alston & Bird

SEC Withdraws Multiple Rule Proposals Affecting Investment Advisers

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The Securities and Exchange Commission (SEC) has retracted 14 rule proposals issued in 2022 and 2023. Our Investment Funds Team examines what the SEC’s withdrawal means for investment advisers going forward....more

Paul Hastings LLP

SEC Withdraws 14 Pending Rule Proposals

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On June 12, the Securities and Exchange Commission (SEC) formally withdrew 14 proposed rules for investment advisers, broker-dealers and public companies, many of which had been pending for several years. Should the SEC...more

Ropes & Gray LLP

SEC Lifts Moratorium on Registering Swiss Investment Advisers

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On June 10, 2025, the SEC issued a press release announcing that, effective immediately, it would resume processing new and pending registration applications of investment advisers with their principal office and place of...more

Mayer Brown

US SEC Gives Green Light to Swiss-Based Investment Adviser Registration Applications

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On June 10, 2025, the US Securities and Exchange Commission (SEC) announced that it will immediately resume processing new and pending registration applications of investment advisers with their principal office and place of...more

Porter Hedges LLP

SEC Shifts Focus to “Rooting Out” AI Abuse

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The Securities and Exchange Commission (SEC) has recently focused on “rooting out” the misuse of artificial intelligence (AI) by publicly traded companies and brokerage firms. On February 20, 2025, the SEC established the...more

Eversheds Sutherland (US) LLP

Preparing for Regulation S-P and takeaways from the SEC’s session at the Incident Response Forum Masterclass 2025

On April 22, 2025, Laura D’Allaird, Chief of the SEC’s Cyber and Emerging Technologies Unit (CETU), participated in the Incident Response Forum Masterclass 2025 (Incident Response Masterclass). In the session, titled “SEC...more

Patomak Global Partners

Key Takeaways from SEC Crypto Task Force Custody Roundtable

Situation Overview: The SEC’s Crypto Task Force is advancing its exploration of regulatory frameworks for digital asset custody. What: The SEC hosted its third roundtable, Know Your Custodian, focusing on challenges and...more

Eversheds Sutherland (US) LLP

Dual registrant regulatory roundup - May 2025

Welcome to the Regulatory Roundup. Each month, Eversheds Sutherland Investment Services attorneys review significant regulatory developments (including notable rulemakings and guidance from securities regulators) from the...more

K&L Gates LLP

What a Relief! Co-Investments Get Easier for Interval Funds, Tender Offer Funds, and Business Development Companies

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The US Securities and Exchange Commission (SEC) has approved a streamlined framework for co-investments involving certain closed-end funds and business development companies (together, Regulated Funds)....more

Moore & Van Allen PLLC

Acting Chairman Uyeda Suggests Revisiting the Role of State Securities Regulators in Connection with Mid-size Investment Advisers...

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On April 8, 2025, then Acting Chairman Mark T. Uyeda of the U.S. Securities and Exchange Commission (“SEC”), highlighted in remarks before the Annual Conference on Federal and State Securities Cooperation two areas where...more

Spilman Thomas & Battle, PLLC

Decoded - Technology Law Insights, V 6, Issue 3, April 2025

Welcome to our third issue of 2025 of Decoded - our technology law insights e-newsletter. We hope you enjoy this issue and thank you for reading. SEC may Reverse Proposed Cryptocurrency Custody Rule and Ohio House...more

Mayer Brown Free Writings + Perspectives

House Financial Services Committee Urges SEC Withdrawal of 14 Proposed and Final Rules

On March 31, 2025, the U.S. House Financial Services Committee (Committee) penned a letter to acting Securities and Exchange Commission (SEC) Chair Mark Uyeda identifying 14 proposed and final rules that, according to the...more

Eversheds Sutherland (US) LLP

Dual registrant regulatory roundup - April 2025

Welcome to the Regulatory Roundup. Each month, Eversheds Sutherland Investment Services attorneys review significant regulatory developments (including notable rulemakings and guidance from securities regulators) from the...more

K&L Gates LLP

United States: House Committee on Financial Services Urges the SEC to Withdraw Final and Proposed Rules

K&L Gates LLP on

On 31 March 2025, the House Committee on Financial Services (Committee), in a letter to Acting Chairman of the US Securities and Exchange Commission (SEC), Mark Uyeda, identified a series of proposed and adopted rules that...more

Vedder Price

SEC Provides Helpful Marketing Rule FAQ Guidance

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On March 19, 2025, the Securities and Exchange Commission (“SEC”) updated its frequently asked questions (FAQs) relating to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the “Marketing Rule”). The new FAQs permit...more

K&L Gates LLP

United States: SEC’s Approach to Artificial Intelligence Begins to Take Shape

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On 27 March 2025, the US Securities and Exchange Commission (SEC) hosted a roundtable on Artificial Intelligence (AI) in the financial industry that was designed to solicit feedback on the risks, benefits and governance of...more

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