On Dec. 18, 2014, the Financial Crimes Enforcement Network (“FinCEN”) 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. FinCEN determined that the CCO “willfully violated” the
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.
Latest from Regulatory & Compliance Update - Page 9
New SEC Cybersecurity Guidance
Cybersecurity continues to be a priority for the Securities and Exchange Commission (SEC). The SEC’s Office of Compliance Inspections and Examinations conducted a cybersecurity “sweep” examination in 2014 and released a summary of its results in early 2015. The SEC’s…
Real Estate Managers Face New Wave of SEC Scrutiny
Real estate fund managers were among the myriad private fund advisers affected by changes to the SEC’s registration requirements under the Dodd-Frank Act in 2011. In the lead-up to the Dodd-Frank registration deadline in March 2012, and for many months…
Model Cybersecurity Contract Terms and Guidance for Investment Managers to Manage Their Third-Party Vendors
Like many companies, investment managers require a wide range of third-party vendor-provided products and services to manage their daily operations. These vendors have varying levels of access to sensitive data, and policies are needed to reduce the cybersecurity risks that…
SEC Examinations of Private Fund Advisers
With new personnel, technology and types of examinations, the U.S. Securities & Exchange Commission has expanded its examination program in an effort to encompass the influx of advisers to private funds, newly required to register by the Dodd-Frank Act.
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The Impact of United States v. Newman on the Use by Investment Advisers of Information Resources
As part of their research process, investment managers gather information from a wide variety of sources. Those sources include: (i) executives and employees of public companies; (ii) competitors; (iii) distributors and suppliers; (iv) sell-side analysts; (v) expert networks; (vi) employees…
Q&A: Legal Defences
As cybersecurity continues to remain a key focus for hedge funds, there is a growing number of questions surrounding the associated legal issues and requirements. Click here to read the interview with HFMTechnology, in which SRZ partners Marc E. Elovitz and…
Proactively Addressing Hedge Fund Cybersecurity Risks
Click here to read this Q&A with The Hedge Fund Journal in which SRZ partner Marc E. Elovitz and special counsel Michael L. Yaeger talk about the growing need for cybersecurity policies for hedge funds, both in light of recent regulatory attention…
BHP Billiton Settles with SEC for $25 Million for Providing Foreign Officials with Luxury Travel to Olympics
The U.S. Securities and Exchange Commission (“SEC”) on May 20, 2015 announced a settlement with global resources company BHP Billiton over allegations that BHP Billiton violated the Foreign Corrupt Practices Act (“FCPA”) by providing luxury travel packages to foreign government…
Information Security: Obligations and Expectations
Information security is not only a good idea — it is also a legal obligation. Federal and state laws impose obligations on businesses, including investment advisers, to keep their data secure. Most of these laws focus on requiring businesses to…