Two recent settlements demonstrate the SEC’s focus on whether RIAs have established, maintained and enforced policies and procedures regarding the use of MNPI.
Registered Investment Advisers (“RIAs”) are facing a new compliance environment under two related proposals targeting money laundering and suspicious financial activity. Last month, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the Securities and Exchange Commission issued a joint Notice of Proposed Rulemaking (“CIP Proposal”) requiring registered investment advisers and exempt...
In the wake of the COVID-19 Pandemic, the SEC has taken emergency steps to address disruption for registered advisers but will also be focusing on certain behaviors to ensure that investors are protected. This webcast replay addressed both these points....
