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cta newsletter webinars


Pay-to-Play Compliance: The 2020 Election and Beyond

The months leading up to the 2020 U.S. Presidential election have seen unprecedented political donations on both sides of the aisle.

Pay-to-play compliance is a concern for firms of all sizes. And it won’t go away after the election. Restrictions on gifts and entertainment and potential lobbyist registration requirements also remain areas of concern. Firms need to have policies and procedures in place to identify potential conflicts of interest—and avoid the fines and reputational damage that those conflicts can bring.

Join us for a complimentary webinar featuring Sonia R. Gioseffi from K&L Gates for an overview of what you need to know to understand and manage pay-to-pay compliance and other compliance concerns with respect to public pension plans, including:

  • A summary of SEC Rule 206(4)-5 and other pay-to-play rules
  • SEC enforcement implications
  • Issues related to gifts and entertainment
  • Potential lobbyist registration requirements
  • Strategies for addressing these risk areas


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Sonia R. Gioseffi
Partner, K&L Gates

Sonia Gioseffi concentrates her practice in the investment management area, and focuses on a variety of regulatory, transactional and counseling matters involving state and federal securities laws. She advises sponsors regarding the organization and regulatory requirements of private equity funds, venture capital funds, hedge funds and other private investment funds. Ms. Gioseffi advises managers and placement agents concerning “pay-to-play” and lobbying regulation and compliance under federal, state and local laws. She also represents public pension plans and other institutional investors in connection with their investments in private investment funds.

Prior to joining K&L Gates, Ms. Gioseffi practiced in the investment management area with other international law firms in San Francisco and Washington, D.C.

Ms. Gioseffi has a B.A. from the University of California, Santa Cruz and earned J.D. and LL.M. degrees from Cornell Law School.