Category Archives: Compliance

The Interplay of “Proactive Compliance” and the SEC:  Take AI, for Example

Historically, the dialogue surrounding compliance among SEC regulated investment advisers has heavily focused on fostering [...]

SEC Fines Private Fund Manager $1 Million for Conflicts Disclosure and Redemption Failures – May 21, 2024

On May 14, 2024, the SEC fined a New York-based private fund manager and its [...]

SEC Adopts Incident Response Planning Rule Under Regulation S-P – May 16, 2024

Have a cybersecurity incident? Investment advisers, broker-dealers, investment companies, and transfer agents included in the [...]

SEC Proposes New Anti-Money Laundering Rule for RIAs and ERAs – May 14, 2024

On May 13, 2024, the SEC proposed a new rule that would require SEC-registered investment [...]

A Failure to Supervise Can Be a Failure to Document…

Early in April, the investment adviser population was hit with another “off-channel” enforcement action from [...]

General Solicitation Under Regulation D – Recent Trends and Enforcement Activity – May 9, 2024

Over the past few years, we have seen a slow-but-steady uptick in 506(c) general solicitation [...]

SEC Issues Risk Alert on Marketing Rule Compliance – April 24, 2024

On April 17, 2024, the SEC’s Division of Examinations (“EXAMS”) issued a Risk Alert which [...]

SEC Fines Five RIAs for Marketing Rule Violations – April 15, 2024

On April 12, 2024, the SEC fined five registered investment advisers for advertising hypothetical performance [...]

SEC Expands Insider Trading Scope by Prevailing in “Shadow Trading” Case – April 9, 2024

On April 5, 2024, a jury in federal court in California found a pharmaceutical executive [...]

SEC Fines Hedge Fund Manager $6.5 Million for Electronic Communications Violations – April 4, 2024

On April 3, 2024, the SEC took a notable enforcement action against Senvest Management, LLC, [...]