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Books and Records in the Regulatory Spotlight

With recent enforcement actions reflecting the Gensler administration’s priority on books and records, can your firm's  audit trail stand up to regulatory scrutiny?

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Minimizing the Risk of CCO Liability

Recent enforcement actions have made it clear that Chief Compliance Officers are at risk of personal exposure if regulatory violations happen under their watch­. The New York City Bar Association recently released a report calling on financial regulators including the SEC and FINRA to adopt a comprehensive and analytical framework for holding CCOs personally liable for violations. 

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Exam Deficiencies for Private Fund Advisers

The SEC Division of Examinations, formerly known as the Office of Compliance Investigations and Examinations (OCIE), provided a discussion of key risks and trends in its 2021 Examination Priorities document.

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Minimum Standards for Compliance Technology

The benefits and affordability of current compliance technology are well known to regulators. Recent SEC guidance and risk alerts have consistently pointed to a lack of adequate technology as a deficiency in compliance programs. Could minimum technology standards for compliance be far behind?

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Look Back to Move Forward: Practical Guidance for Compliance in 2021

Taking a look back can help you move forward. Now’s the time to take a step back and consider how new or elevated risks during the year have been addressed, how controls have been established, and how compliance initiatives undertaken at year-end can set the stage for a stronger compliance program in 2021.

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