Happy New Year and Important Reminders Regarding CCO Liability
As we begin a new year, our thoughts turn to our clients and friends who have made our progress possible. We are grateful to our
How to Make $13 Million Before the New Year
The SEC announced on December 13 that they have brought charges against a New Jersey man and his company for allegedly committing fraud in a
SEC Raises Awareness Surrounding CCO Outsourcing
Yesterday, the SEC indirectly affirmed that registered investment advisers and investment companies can outsource their CCO to an unaffiliated third party and satisfy their 206(4)-7(c)
SEC Provides Clarity on When and How the Enforcement Division Goes After CCOs
Yesterday, Director of the Enforcement Division of the Securities and Exchange Commission, Andrew Ceresney was the keynote speaker at the National Society of Compliance Professionals
The SEC Outdoes Itself Again Announcing A Record Year for Enforcement Action
The Securities and Exchange Commission announced on October 22, 2015 a comprehensive report describing the results of enforcement actions taken against advisers in fiscal year
The Hunt Continues: SEC Goes After Large Private Equity Firm for Undisclosed Fees
On October 7, 2015, the SEC announced a large settlement with a private equity firm charged with failure to disclose. The SEC said that the
COMPLIANCE SCIENCE SUMMIT 2015
When: November 17, 2015 Where: Convene Midtown East | 730 Third Avenue | New York, NY 10017 Janaya Moscony, President, SEC Compliance Consultants, Inc. will
Adviser Settles SEC Cyber Enforcement Action
The Securities and Exchange Commission announced on September 22, 2015 that an investment adviser has agreed to settle charges that it failed to establish the
First Case Brought Under Distribution-in-Guise Initiative
On September 21, 2015, the Securities and Exchange Commission charged an asset manager with improperly using mutual fund shareholder’s assets to pay two unnamed brokerage
New Cybersecurity Risk Alert Announcing Second Round of Cybersecurity Sweep Exams
On September 15, 2015, the Office of Compliance Inspections and Examinations (“OCIE”) issued a new Risk Alert relating to cybersecurity. This Risk Alert reemphasized the intention
CHIEF COMPLIANCE OFFICER ROUNDTABLE: BREAKFAST BRIEFING
When: October 13, 2015 Where: Blank Rome LLP | The Chrysler Building | 405 Lexington Avenue | New York, NY 10174 22nd Floor Boardroom Thomas
Anti-Money Laundering Regulation—Third Time’s the Charm?
The Financial Crimes Enforcement Network (FinCEN) proposed on August 25, 2015, a rule that would require certain registered investment advisers to have in place anti-money