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Securities and Exchange Commission (SEC) Investment Management Enforcement Actions

Blank Rome LLP

Regulatory Update and Recent SEC Actions, July 2025

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Recent SEC Administration Changes - SEC Names Brian Daly as Director of the Division of Investment Management - On June 10, 2025, the Securities and Exchange Commission (the “SEC”) announced that Natasha Vij Greiner,...more

Latham & Watkins LLP

SEC Withdraws Proposed Rule on ESG Disclosures for Investment Advisers and Investment Companies

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The withdrawal aligns with the SEC’s “back to basics” approach, but it does not preclude scrutiny of ESG in asset managers’ strategies, marketing, and fund documentation....more

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

Proskauer - The Capital Commitment

SEC Regulation in a Non-Regulatory Environment

With Paul Atkins as the new SEC Chair, the agency’s priorities have shifted away from many of the aggressive policies of former Chair Gensler. The first four months of the Republican controlled SEC saw a dramatic shift in the...more

Proskauer - The Capital Commitment

Regulatory Scrutiny on Potential MNPI in the Credit Markets

Over the past year, regulatory scrutiny of the credit markets has intensified, with the SEC investigating the potential use of material nonpublic information (“MNPI”) relating to credit instruments. The SEC brought a number...more

DLA Piper

IMpact: Investment Management News - Q2 2025

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Welcome to IMpact: Investment Management News. In this regular bulletin, DLA Piper lawyers share their insights on key developments that are impacting the investment management industry. Pursuant to rules issued in 2024 and...more

Woodruff Sawyer

Looking Into the SEC Future for Financial Services Companies

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As new Chair Paul Atkins begins to make his mark on the Securities and Exchange Commission, the news cycle has been heavily focused on crypto regulation. The SEC, however, is more than just a crypto regulator....more

Carlton Fields

Expect Focus - Volume II, May 2025

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Builder of Investment Models Deviates From Blueprints Employee’s Rogue Remodeling Costs Builder Plenty - The SEC’s recent order instituting administrative and cease-and-desist proceedings (OIP) against registered...more

Carlton Fields

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

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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

Carlton Fields

Recent SEC AML Enforcement Actions and Likely Continued AML Emphasis Under New Administration

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Registered investment advisers have until January 1, 2026, to comply with the anti-money laundering (AML) compliance provisions of the Bank Secrecy Act (BSA). However, the SEC has recently charged two investment advisers with...more

Seward & Kissel LLP

SEC Voluntarily Dismisses Action against Hedge Fund Manager over Safeguarding Confidential Information while Participating on...

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On April 7, 2024, the United States District Court for the District of Connecticut approved the Securities and Exchange Commission’s request to dismiss its action against a hedge fund manager for the manager’s alleged failure...more

SEC Compliance Consultants, Inc. (SEC³)

February and March 2025 Regulatory Roundup

SEC Clarifies Marketing Rule, Warms up to Crypto and Private Placements under 506(c), and Backs off Form SHO; Latest Lessons from EXAMS: Duty of Care and Risk Identification Failures - Welcome to our February and March 2025...more

SEC Compliance Consultants, Inc. (SEC³)

Predictions for 2025: What Private Fund Advisers Can Expect from SEC Examinations

There has been a lot of conjecture that the SEC may become friendlier to registrants because of the new administration. Given the SEC’s mandate to protect the investing public, however, we do not expect SEC examiners to...more

Vedder Price

SEC Settles Enforcement Proceedings Against Quantitative Hedge Fund Manager for Alleged Algorithmic Model Vulnerabilities

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On January 16, 2025, the SEC announced the settlement of administrative proceedings brought against a hedge fund manager that used algorithmic investment models to provide investment advice to its private fund and separately...more

Polsinelli

Beyond the Blockchain: What’s Next for Digital Assets After Explosive Growth in 2024

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Web3 represents the next evolution of the internet, characterized by decentralized networks and blockchain technology, enabling user-centric platforms and applications with enhanced security and data ownership. Digital...more

Seward & Kissel LLP

SEC Charges Investment Advisers for Compliance Failures Relating to Cash Sweep Programs

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Quick Take: Indicative of a recent SEC focus on bank deposit sweep programs (BDSPs) offered to advisory clients through broker-dealers, the SEC recently settled charges against three dually registered investment advisers and...more

Morgan Lewis

Developments in SEC and FINRA Enforcement and Exams for Investment Advisers and Broker-Dealers: 2024–2025

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The US Securities and Exchange Commission (SEC) brought a number of significant enforcement proceedings against investment advisers and broker-dealers in FY 2024 and during the first quarter of FY 2025. If history serves as a...more

Winstead PC

SEC Renewed Action on Hedge Clauses

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Hedge clauses are provisions in investment advisory agreements that aim to limit an adviser’s liability for certain actions or outcomes. The U.S. Securities and Exchange Commission (the “SEC”) has expressed the position that...more

K&L Gates LLP

Asset Management Regulatory Year in Review 2024

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2024 was a year of meaningful regulatory change for asset managers globally. The regulatory activity was wide ranging and without a particular unifying theme. In fact, the wide, and in cases diverging focuses of key global...more

Proskauer - Regulatory & Compliance

SEC Extends Compliance Date for Short Sale Reporting Rule to 2026

On February 6, 2025, the SEC announced that it was providing a temporary exemption from compliance with Rule 13f-2 under the Securities Exchange Act of 1934 (the “Exchange Act”), which establishes a mandatory short reporting...more

Morrison & Foerster LLP

Extended Compliance Date for Recent Form PF Amendments

The new year always marks the start of a busy regulatory filing season for registered investment advisers, including investment advisers that file Form PF (“Form PF Filers”). This year could be especially challenging since,...more

Morgan Lewis

Current Developments in SEC Enforcement for Private Funds and a Look Ahead 2024–2025

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In 2024, private funds continued to be a major focus for the US Securities and Exchange Commission (SEC), with an active docket of enforcement cases and rulemaking efforts. Although we expect 2025 to include a continued...more

WilmerHale

Cross-Trading at a Crossroads

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Once upon a time, in 1994, when I was a young lawyer in the SEC’s Division of Investment Management (Division), Office of Chief Counsel, we received a request to modify a previously granted but totally impractical no-action...more

Morgan Lewis

Securities Enforcement Roundup – December 2024

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In this issue of our monthly Securities Enforcement Roundup, we highlight top securities enforcement developments and cases from December 2024. In December 2024: President-elect Trump nominated former SEC Commissioner Paul...more

Royer Cooper Cohen Braunfeld LLC

The Pitfalls of “Green Washing”

In a significant development for the investment management industry, a large adviser agreed to pay a hefty $17.5 million civil penalty to settle charges with the SEC over misleading statements about its Environmental, Social,...more

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