FinCEN’s Investment Adviser Rule will, as of January 1, 2026, require certain investment advisers to implement and maintain AML/CFT compliance programs and monitor for and report suspic...
In this issue we discuss, among other things, amended reporting requirements for registered funds and SEC guidance regarding open-end fund liquidity risk management programs, as well as r...
In this issue, we discuss a recent enforcement action involving a private fund adviser that allegedly included misleading performance information in advertisements in violation of the Mar...
In this issue, we discuss the U.S. Court of Appeals decision that struck down the SEC’s new rules and amendments under the Advisers Act regarding private fund advisers.
In a closely watched case, the U.S. Court of Appeals for the Fifth Circuit struck down in its entirety the SEC’s new private fund advisers rule on the grounds that the rule exceeded the...
In this issue, we discuss proposed customer identification requirements for investment advisers and amendments regarding expanded cybersecurity requirements for broker-dealers, investment...
In this issue, we discuss the SEC Examinations Division’s risk alert regarding compliance with the Advisers Act Marketing Rule, and recent enforcement actions involving, among other thi...
In this issue, we discuss recent enforcement actions involving investment advisers that allegedly made false and misleading statements about their use of artificial intelligence.
In this issue, we discuss among other things updated FAQs regarding compliance with the marketing rule under the Advisers Act, and amendments to Form PF.
FinCEN issued its long-awaited proposed rule that would impose AML/CFT obligations on certain investment advisers, such as requirements to implement and maintain an AML/CFT compliance pro...