Financial regulators are emphasizing the risk poor cybersecurity poses to market integrity and financial stability, and elaborating on policies and controls they expect the firms they oversee to have in place. Investment managers’ responsibility for cybersecurity has grown like compound
Regulatory & Compliance Update
News, insight and market knowledge on regulatory and compliance issues from Schulte Roth & Zabel
Regulatory & Compliance Update, published by Schulte Roth & Zabel LLP, covers developments in financial regulation and compliance, focusing on securities laws, investment company regulations, and sanctions programs. The blog addresses regulatory changes affecting exchange-traded funds (ETFs), private funds, and banking entities, including updates on the Volcker Rule and SEC rulemakings. It also reports on enforcement trends, cybersecurity and data protection requirements, and international sanctions impacting jurisdictions such as Iran and Venezuela. The blog provides summaries of regulatory agency guidance, rule proposals, and final rules relevant to investment advisers, broker-dealers, and financial institutions.
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Cybersecurity Update: Takeaways from OCIE’s Examination Initiative and the NFA’s Rulemaking Proposal
As the end of 2015 approaches, financial regulators continue to emphasize the risk that poor cybersecurity poses to market integrity and financial stability, and to elaborate on the policies, procedures and controls they expect investment advisers, commodity pool operators and…
CFTC Determines That Bitcoin and Other Virtual Currencies Are Commodities
n Sept. 17, 2015, the Commodity Futures Trading Commission issued an order against an online platform (and against its sponsor) for facilitating the trading of Bitcoin options contracts.[1] The Order is based on the activities of Francisco Riordan, the chief…
The New AML Rules: Implications for Private Fund Managers
On Aug. 25, 2015, the Financial Crimes Enforcement Network (“FinCEN”) issued for public comment a proposed rule (the “Proposed Rule”) requiring investment advisers registered with the SEC (“RIAs”) to establish anti-money laundering (“AML”) programs and report suspicious activity to FinCEN…
Federal and State Regulators Target Compliance Officers — Part II
On Dec. 18, 2014, the Financial Crimes Enforcement Network issued a first-of-its-kind $1-million assessment against the former chief compliance officer and senior vice president of government affairs at MoneyGram International Inc. Separately, on Dec. 22, 2014, Bank Leumi USA and…
New Anti-Money Laundering Rules for Registered Investment Advisers Proposed by FinCEN
Today, Aug. 25, 2015, the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury, issued for public comment a proposed rule requiring investment advisers registered with the SEC (“RIAs”) to establish anti-money laundering (“AML”) programs…
SRZ Submits Comment Letter on SEC’s Proposed Amendments to Form ADV and Investment Advisers Act Rules
SRZ on Aug. 11, 2015 submitted comments to the U.S. Securities and Exchange Commission on the agency’s proposed amendments to Form ADV and the corresponding rules under the Investment Advisers Act. SRZ’s comment letter addresses confidentiality concerns about the proposal’s obligation…
Manufacturers Vulnerable to Theft of Trade Secrets
By Bryan Daly
Systems that allow manufacturing companies to control industrial machinery remotely present additional cyber risk when it comes to the protection of trade secrets. Security experts are advising boards of such companies to include these often-overlooked systems in cyber-risk reviews. The…
Case Study: Form ADV
By Bryan Daly
In the proposing release for the Form ADV amendments, the SEC is asking advisers to provide substantial amounts of information on their managed accounts. The new information gathered on Form ADV is meant to be a complement to Form PF…
AIFMD Update: ESMA Advice on Extension of Marketing Passport Published
On 30 July 2015, the European Securities and Markets Authority (‘ESMA’) published its advice to the European Parliament, the Council and the Commission on the extension of the marketing passport to non-EU alternative investment managers (‘AIFMs’) and alternative investment funds…