SEC Finds Deficiencies in Disclosing Conflicts of Interest and MNPI

The Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) recently published the Risk Alert Observations from Examinations of Investment Advisers Managing Private Funds. 

 

The Risk Alert covers three general areas of deficiencies that the OCIE has identified in examinations of private fund advisers: conflicts of interest, fees and expenses, and policies and procedures relating to material non-public information (MNPI). The alert outlines concerns and compliance issues observed during examinations of registered investment advisers that manage private equity funds or hedge funds—and serves notice that the SEC will continue to put a high priority on customer well-being.

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FAA Enforcement Committee Hands Down First-Ever Decision

The French Anticorruption Agency (FAA) made an unsuccessful attempt to take its first enforcement this July as reported by a JD Supra news alert. The move followed the regulator’s three-month audit of an undisclosed company's corporate compliance program.  

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Possibility of Individual Accountability Regime in South Africa?

South Africa recently introduced a new regulator and regulatory framework whose primary objective is to supervise the conduct of business of all financial institutions there. The Financial Sector Conduct Authority (FSCA) represents a distinct change in the country’s approach to regulation of its financial services industry. 

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US Supreme Court Ruling should Spur Anti-corruption Efforts

The U.S. Supreme Court recently held protections in the International Organizations Immunities Act of 1945 against civil lawsuits in U.S. courts were not absolute. Instead, immunity granted to international organizations, including Multilateral Development Banks (MDBs), is no greater than that enjoyed by foreign governments under the Foreign Sovereign Immunities Act (FSIA).  

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FINRA Fines - 2017 Summary

*The data collected is from January - November 2017.

We have tracked the monthly and quarterly disciplinary actions taken by FINRA against member firms in 2017 and present to you 6 takeaways we have identified by delving into the numbers behind the released enforcement actions.

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