News & Analysis as of

Investment Management Penalties

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for May 2025

On May 14, 2025, Deputy Enforcement Director Antonia Apps told those gathered at an anti‑money laundering conference in Washington, D.C. to expect a more measured approach from SEC Enforcement. That may include, she...more

Lowenstein Sandler LLP

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

Lowenstein Sandler LLP on

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

Carlton Fields

Builder of Investment Models Deviates From Blueprints - Employee’s Rogue Remodeling Costs Builder Plenty

Carlton Fields on

The SEC’s recent order instituting administrative and cease-and-desist proceedings (OIP) against registered investment advisers Two Sigma Investments LP and Two Sigma Advisers LP illustrates significant risks for investment...more

Seward & Kissel LLP

Updated Alert: FinCEN Imposes New Reporting Requirements on LLCs and other Entities

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As a reminder to our clients and friends of the firm, the beneficial ownership reporting deadline is soon approaching. Applicable entities that were formed or registered to do business in the U.S. prior to this year, have...more

Akin Gump Strauss Hauer & Feld LLP

The Impact of the General Data Protection Regulation on Investment Managers

The new European General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR) will take effect on 25 May 2018. The GDPR expands and clarifies the EU’s existing personal data protection framework. Investment managers...more

Vedder Price

Investment Services Regulatory Update - February 2018

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New Rules, Proposed Rules, Guidance and Alerts – SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues Guidance on Cryptocurrency-related Holdings - On January 18, 2018, the staff of the SEC’s Division of Investment...more

Vedder Price

Investment Services Regulatory Update - October 2017

Vedder Price on

New Rules, Propsed Rules, Guidance and Alerts - SEC STAFF GUIDANCE AND ALERTS - SEC Staff Extends No-Action Relief on Auditor Independence and the “Loan Provision” - On September 22, 2017, the staff of the SEC’s...more

Broker-Dealer Compliance + Regulation

Double-Check the Math: Advisers Should Not Provide Clients With Performance Data Created by Other Investment Managers Without...

In a series of enforcement actions this week, the SEC made it clear that investment advisers need to substantiate the performance records of investment management firms they recommend to their clients. In these cases,...more

King & Spalding

SEC Steps Up Scrutiny On Private Fund Fee Allocation Practices

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In two recent cases, the Securities and Exchange Commission (the SEC) has made clear that it has increased its focus on private funds and their allocation of fees and expenses. In the most recent, the SEC entered an order on...more

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