SEC Compliance Program for EU Investment Advisers - Introduction


A Compliance Officer's Best Tools and Tips for the SEC Exam Process

On September 13, MyComplianceOffice co-hosted a webinar with Milne Legal. Our presenters Dustin Milne, Charles Lerner and Laetitia Mantel discussed what an investment advisory firm outside of the US needs to consider when dealing with the US. This included discussions on what defines a US person, when to register with the SEC, how to handle a SEC exam and what sort of compliance program you should have in place.

 You can download a full copy of the slides from this webinar.


Full video transcript available below:

Today we have our friends from Milne Legal. I'd like to introduce you to Dustin Milne who is the founder and managing partner, Charles Learner who is the senior advisory and regulatory consultant, and he's also principle of judiciary compliance and associate at LLC located in New York. Latisha Monto who is a senior compliance consultant, Milne Legal. I'll hand you over to Dustin now. Dustin?

Thank you, Shane. First of all, on behalf of Milne Legal I'd like to issue a warm welcome for all of our participants who have dialed in today for this webinar. We do clearly believe it's an important subject, so we are happy to have each of you participating on the phone with us today. Like Shane explained, my name is Milne Legal. I am the founder of Milne Legal and the managing partner. I'm also a U.S. licensed lawyer out of the state of New York, specifically focusing my practice on the SEC regulatory issues and on the U.S. tax side as well, on behalf of the firm.

Charles Learner, to my right sitting here with me. It's clearly a pleasure to have him. He brings a tremendous amount of senior experience with the government working several years with the SEC enforcement division. He will share his thoughts later in the program. It's clearly a privilege to have him. 

I'm also joined by Latisha Monto who has had over ten years of experience working in the U.S. space, specifically for non-U.S. organized investment advisers registered with the SEC focusing on their compliance programs. She's going to share some of her experience later on in the presentation.

Before we dive into the material topics, maybe a quick note on the Milne Legal - thank you, Shane, for flipping the slide. Milne Legal is boutique law firm organized in Zurich. We also have a branch office in Paris. The members of our firm are all U.S. Lawyers or compliance consultants. We don't practice any non-U.S. laws, specifically U.S. laws regulatory.

Today's agenda: we have three points. I'll address the first one, the definitions. Who qualifies as an investment adviser under the 1940 Investment Advisers Act? What is U.S. jurisdictional means, and U.S. person mean? All three are important in deciding whether your entity organized outside the United States indeed has to register. Latisha Monto will touch upon the compliance program. If it is determined that you do need to register under the act you need the compliance program, certain books and records. Latisha will talk about that. We'll shift to Charles at the end of the presentation who will talk about preparing for an SEC examination and some relevant SEC enforcement actions that have taken place against entities organized outside the united states. We'll bring those to your attention.

 This webinar was co-hosted with Milne Legal. To learn more visit

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