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Recordkeeping Requirements Chief Compliance Officers

Foley & Lardner LLP

SEC Intensifies Scrutiny of Chief Compliance Officers

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Two recent SEC enforcement actions serve as a sharp reminder that Chief Compliance Officers (CCOs) can face personal liability for what they do – or fail to do – in the course of regulatory examinations for registered...more

Proskauer Rose LLP

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

Proskauer Rose LLP on

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

Society of Corporate Compliance and Ethics...

The SEC’s cybersecurity and disclosure rules: The questions compliance pros still have

The U.S. Securities and Exchange Commission (SEC) Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure rules officially went into effect in December 2023. Aimed at improving cybersecurity risk...more

Lowenstein Sandler LLP

Another Wave of SEC Settlements Underscore the Continued Priority of Record Retention Communication Compliance

On August 14, 2024, the U.S. Securities and Exchange Commission (SEC) announced another series of settlements regarding “off-channel communications.”1 As part of its Off-Channel Communications Initiative,2 the SEC settled...more

PilieroMazza PLLC

Managing Small Business Risk, Part I: Expect Litigation Even When It Seems Unlikely

PilieroMazza PLLC on

No business wants to be investigated or charged by the government, sued by a competitor, or compelled to defend against an employment lawsuit. The risks of such litigation to any company are so predictable, though, that large...more

The Volkov Law Group

Episode 312 -- Eddie Green, CEO SnippetSentry, on Communications Preservation Risks

The Volkov Law Group on

Companies have a vested interest in preserving internal communications for a variety of reasons — to hold actors accountable and to protect the organization from potential private and government claims or investigations that...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Proposes New Rule to Expand Anti-Money Laundering Requirements for Investment Advisers

Key Points - On February 13, 2024, FinCEN issued an NPRM that seeks to include certain investment advisers in the definition of “financial institution” under the BSA. As described in the NPRM as well as in FinCEN’s fact...more

Vicente LLP

[Webinar] Common Massachusetts Cannabis Business Compliance Pitfalls

Vicente LLP on

Have no doubt, once the COVID-19 pandemic safety restrictions loosen, the Massachusetts Cannabis Control Commission will resume business as usual. This will likely include unannounced on-site compliance audits of licensed...more

Lowenstein Sandler LLP

2020 and Q1 2021 Developments And Annual Compliance Checklists

Summaries of recent legislative and regulatory developments with respect to: •The SEC’s Examination Priorities for 2021- •The SEC’s Focus on Digital Asset Securities- •The SEC’s New Marketing Rule... ...more

Health Care Compliance Association (HCCA)

[Virtual Event] 2020 Seattle Regional Conference - June 5th, 8:30 am - 4:15 pm PDT

Our Virtual Regional Healthcare Compliance Conferences provide updates on the latest news in regulatory requirement, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask...more

American Conference Institute (ACI)

[Virtual Forum] Anti-Money Laundering and Financial Crime - July 14th - 15th, 8:00 am - 5:00 pm EDT

Virtually attend the forum to learn how to align your compliance program with the amended Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) regulations effective 2020/2021. In June 2019 amended...more

Katten Muchin Rosenman LLP

Bridging the Weeks - October 2019

Last week, the Commodity Futures Trading Commission publicized a cascade of settlements of enforcement actions alleging breaches of laws and rules related to supervision, spoofing, reporting, and misappropriation of...more

Proskauer - Government Contractor Compliance...

OFCCP Publishes New Compliance Assistance Guides

When OFCCP issued its “Town Hall Action Plan ” in May 2018, it stated its commitment to “review and enhance contractor compliance assistance materials.” In furtherance of this commitment, on August 2, 2019, OFCCP announced...more

The Volkov Law Group

Make Sure You Address Compliance with Export Controls

The Volkov Law Group on

Compliance officers have to avoid professional myopia. The focus of compliance these days has been on anti-corruption, antitrust, and AML, depending on your company’s industry. They fit nicely together under an...more

Eversheds Sutherland (US) LLP

Legal Alert: New York’s New BSA/AML Rule Imposes Monitoring, Filtering and Certification Requirements

On June 30, 2016, the New York Department of Financial Services (DFS) adopted a new anti-terrorism and anti-money laundering (AML) regulation (Final Rule) that builds on federal anti-money laundering requirements to address...more

Morrison & Foerster LLP

FinCEN Proposes Anti-Money Laundering and Suspicious Reporting Rules for Registered Investment Advisers

On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more

Proskauer - Corporate Defense and Disputes

Proposed AML Regulations for Registered Investment Advisers Released by FinCEN

On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released proposed rules that would require investment advisers that are registered or required to be registered (RIAs)...more

Troutman Pepper Locke

The Foreign Corrupt Practices Act: At a Glance

Troutman Pepper Locke on

In this issue: - FCPA AT A GLANCE - THE ANTI-BRIBERY PROVISIONS OF THE FCPA - TO WHOM THE ANTI-BRIBERY PROVISIONS APPLY - THE PAYMENT ELEMENT - THE CORRUPT INTENT ELEMENT - WHO IS A...more

Morgan Lewis

SEC Proposes Rules to Enhance Information Reported by Investment Advisers

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The proposed rules would require expanded reporting about separately managed accounts and other aspects of an adviser’s business, allow consolidated registrations for certain private fund advisers that operate a single...more

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