Anitra T. Cassas

Anitra represents broker-dealers, investment advisers, municipal advisors private equity and hedge funds, banks and individuals in connection with government investigations, compliance examinations and internal audits.

Firm/Organization: McGuireWoods LLP

Blogs: Subject to Inquiry

Latest Articles

Subject to Inquiry

SEC Continues Compensation Disclosure Focus With FAQs and Enforcement

By Anitra T. Cassas, Emily P. Gordy, Cheryl Haas & Aline McCullough

November 20, 2019

On Oct. 18, 2019, the Securities and Exchange Commission (SEC) Division of Investment Management staff published Frequently Asked Questions Regarding Disclosure of Certain Financial Conflicts Related to Investment Adviser Compensation (FAQs). Many in the industry view the FAQs as overdue SEC guidance in an area that has been a focus of the SEC Division of Enforcement. Registered investment advisers (RIAs) should review the FAQs in light of continuing enforcement actions in this area, including the…

Subject to Inquiry

D.C. Circuit Vacates SEC Sanctions, Says Negligent Omissions Are Not ‘Willful’ Under Advisers Act

By Anitra T. Cassas, Emily P. Gordy, Cheryl Haas & Amanda J. Goldstein

May 14, 2019

On April 30, the U.S. Circuit Court of Appeals for the District of Columbia Circuit vacated a Securities and Exchange Commission order imposing sanctions. The court held that an investment advisory firm and its owners did not violate Section 207 of the Investment Advisers Act of 1930, 15 U.S.C. § 80b-7, by negligently omitting material facts from the firm’s Form ADV. (See Robare Group, Ltd., et al. v. SEC, No. 16-1453.) In September 2014, SEC Enforcement charged…

Subject to Inquiry

SEC Opens Cease-and-Desist Order Proceeding against Broker-Dealer and Chief Compliance / AML Officer

By Anitra T. Cassas & Jeffrey M. Hanna

March 13, 2017

As we have highlighted in prior posts, regulators of financial institutions, including FinCEN, FINRA and SEC, have increasingly brought actions to bring organizations – and individuals – into compliance with AML / BSA obligations. This enforcement activity is consistent with FinCEN’s August 2014 Advisory, now nearly three years old, emphasizing the idea that U.S. financial institutions must promote a culture of compliance, one that does not allow the pursuit of profits to overshadow obligations…

Anitra T. Cassas

SEC Continues Compensation Disclosure Focus With FAQs and Enforcement

D.C. Circuit Vacates SEC Sanctions, Says Negligent Omissions Are Not ‘Willful’ Under Advisers Act

SEC Opens Cease-and-Desist Order Proceeding against Broker-Dealer and Chief Compliance / AML Officer

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