Compliance Tip of the Day: Rethinking Corporate AI Governance Through Design Intelligence
Compliance Tip of the Day: COSO Governance Framework: Part 4, Culture
Compliance Tip of the Day: COSO Governance Framework: Part 1, Introduction
Compliance Tip of the Day: Internal Control Deficiencies
FCPA Compliance Report: Stay the Course: Ellen Lafferty on Navigating Anti-Corruption Compliance in 2025
Adventures in Compliance: The Novels – The Hound of the Baskervilles, Introduction and Compliance Lessons Learned
Compliance Tip of the Day: Assessing Internal Controls
Key Discovery Points: BYOD Case Law Covering Subpoenas and Employee Handbooks
Compliance Tip of the Day: COSO Objective 5 – Monitoring Activities
Compliance Tip of the Day: COSO Objective 4 - Control Information and Communication
Hospice Insights Podcast - Election Inspection: Be Proactive to Avoid Costly Election Statement Denials
Compliance Tip of the Day: COSO Objective 3 – Control Activities
Compliance Tip of the Day – COSO Objective 1 – Control Environment
Compliance Tip of the Day: Code of Conduct as an Internal Control
Rethinking Records Retention
Compliance Tip of the Day: Internal Controls for GTE
FCPA Compliance Report: Revolutionizing Speak Up: Ariel D. Weindling on Enhancing Whistleblower Systems
Compliance Tip of the Day: Implementing Internal Controls
Podcast: Addressing Patient Complaints About Privacy Violations
Compliance Amidst a Global Consensus Breakdown
Private fund advisers continually balance their ongoing responsibility to ensure that the funds they advise comply with such funds’ governing documents and their responsibility to ensure their own compliance with applicable...more
Chief Compliance Officers face the challenge of running a comprehensive yet efficient compliance program that nimbly adapts to changing regulatory requirements and business practices. As compliance consultants, we see our...more
Many compliance officers live in hope that if they ramp up their persuasive skills, engage employees with spectacular training presentations, and provide succinct and prompt advice, they will receive the respect and...more
Who may be interested: Registered Investment Companies; Registered Investment Advisers; Compliance Officers - Quick Take: The SEC charged a hedge fund manager registered as an investment adviser (Adviser) with failing to...more
These days, artificial intelligence is everywhere we look, and the financial services industry is no different. As AI use increases, regulatory bodies are updating their rules and guidelines detailing how companies should and...more
In addition to basic blocking and tackling, compliance officers often have the thankless job of performing the annual review of their compliance program required by Advisers Act Rule 206(4)-7....more
The Securities and Exchange Commission (SEC) recently brought settled enforcement actions against two registered investment advisers for failing to establish, maintain, and enforce written policies and procedures reasonably...more
In a two-part legal update, we will discuss key information SEC registrants should know going into the upcoming review cycle conducted by the Division of Examinations (the Division). This first update attempts to demystify...more
On August 28, the Financial Crimes Enforcement Network (FinCEN) issued a final rule establishing anti-money laundering and countering the financing of terrorism (AML/CFT) compliance obligations for US Securities and Exchange...more
On October 21, 2024, the Division of Examinations (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC”) issued its annual examination priorities for fiscal year 2025. As with its 2024 examination...more
Who may be interested: Registered Investment Advisers, Registered Investment Companies, Compliance Staff - Quick Take: The SEC recently announced a number of additional enforcement actions relating to recordkeeping...more
Who may be interested: Investment Advisers; Compliance Staff - Quick Take: The SEC announced that it had settled charges against a registered investment adviser (Adviser) for failing to establish, maintain, and enforce...more
Most compliance officers struggle to determine whether they are conducting enough testing to satisfy their obligations under the Advisers Act. In its release adopting Advisers Act Rule 206(4)-7, the SEC stated that an...more
Covered institutions will need to review their cybersecurity and incident response policies and procedures ahead of the applicable compliance deadline. The Securities and Exchange Commission (SEC) recently adopted...more
The SEC recently took action against Gainvest Legal Corp. and its owner. This action serves as a stark reminder for others in the financial services industry about the importance of a custom-tailored compliance program and...more
SEC DROPS NEW REQUIREMENT FOR INCIDENT RESPONSE PROGRAMS, PROPOSAL FOR RIAS TO ADOPT CIP, SEC EXAMS SHARES MARKETING RULE FAILURES, RIA SLAMMED FOR FAILING TO RETAIN TEXTS, AND SEC WINS ON SHADOW TRADING THEORY - Welcome to...more
On May 16, 2024, the U.S. Securities and Exchange Commission (“SEC”) adopted amendments to Regulation S-P (“Reg S-P”) that are intended to help protect investors’ privacy from the “expanded use of technology and corresponding...more
SEC’s Division of Examinations (“EXAMS”) issued a risk alert on its Initial Observations Regarding Advisers Act Marketing Rule Compliance (the “Risk Alert”), giving compliance officers an unexpected gift by sharing examples...more
On April 17th, the SEC issued a Risk Alert titled “Initial Observations Regarding Advisers Act Marketing Rule Compliance.” Perusing the list of failures, a sense of familiarity arose, given that one of our clients had been...more
Starting May 28, 2024, the settlement cycle for most transactions in U.S. securities will shorten from T+2 to T+1 as a result of rule amendments adopted by the Securities and Exchange Commission (SEC).1 The SEC also adopted a...more
Rule 206(4)-1, as amended (the Marketing Rule), continues to be an area of focus for the U.S. Securities and Exchange Commission (SEC). On April 17, 2024, the SEC Division of Examinations (Division) published a risk alert...more
Many chief compliance officers struggle every year with preparing the annual review required under Advisers Act Rule 206(4)-7. To help you out, here’s our guide to writing your annual report....more
On April 17, 2024, the Division of Examinations (the “Division”) of the Securities and Exchange Commission (the “SEC”) published a Risk Alert entitled: “Initial Observations Regarding Advisers Act Marketing Rule Compliance”...more
The Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory Authority (“FINRA”) have, in two separate recent settled enforcement actions involving off-channel communications (“OCC”), imposed fine...more
Overview - On 3 April 2024, the US Securities and Exchange Commission (the SEC) announced the first settlement with a stand-alone registered investment adviser for, among other things, failures to maintain and preserve...more