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Recordkeeping Requirements Investment Advisers Act of 1940 Penalties

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

A&O Shearman

SEC Enters Into Off-Channel Settlements With Twelve Additional Firms Prior To Leadership Turnover

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On January 13, 2025, one week before Chair Gary Gensler is expected to step down as Chair, the Securities and Exchange Commission (“SEC”) announced settlements with twelve additional regulated entities for alleged...more

Akin Gump Strauss Hauer & Feld LLP

“Under the Wire” E-Comms Settlements: More Confusion Than Closure

On January 13, 2025, the U.S. Securities and Exchange Commission announced settled enforcement actions with five registered investment advisers for failing to maintain and preserve internal electronic communications. These...more

Seward & Kissel LLP

Continued SEC Enforcement Actions Relating to Off Channel Communications

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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

Seward & Kissel LLP

SEC Charges 11 Firms with Widespread Recordkeeping Failures

Seward & Kissel LLP on

Who may be interested: Registered Investment Advisers, Broker-Dealers, Registered Investment Companies, Boards of Directors - Quick Take: The SEC recently settled charges against ten broker-dealers and one dually...more

Seward & Kissel LLP

SEC Charges Sixteen Firms for Recordkeeping Failures Related to Employee Use of Personal Devices

Seward & Kissel LLP on

On September 27, 2022, the Securities and Exchange Commission (“Commission”) entered into a series of settled orders (“Orders”) against 15 broker-dealers and one affiliated investment adviser for widespread failures by the...more

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