On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a final rule to protect the U.S. financial system from illicit activity in the investment adviser sector. This rule targets criminals, foreign adversaries, and others attempting to
On June 27, 2024, Northern Rockies Regional Center, LLC received a “Notice of Intent to Terminate” from the United States Citizen and Immigration Services (USCIS) due to the non-payment of its 2024 EB-5 Integrity Fund fee by December 30, 2023.
The EB-5 Immigrant Investor Program offers foreign nationals a pathway to U.S. residency through investment. Through the program, there are two investment options: direct investment and regional center investment. Both pathways aim to stimulate the U.S. economy through job creation,
At times, people ask me whether there is one state in particular that is optimal for investment adviser registration purposes. I am quick to point out that the requirement to register an investment adviser in a certain state depends on
Over the past few years, I have been asked a handful of times whether a registered investment adviser may outsource the role of the Chief Compliance Officer. While there are compliance firms that offer such a service, I personally discourage
Each year, registered investment advisers and exempt reporting advisers are required to draft their annual updating amendment and file it within 90 days of their fiscal year end, which in most cases is March 31st.
Responses to all items must
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On September 6th, the U.S. Securities and Exchange Commission issued a Risk Alert, providing investment advisers with information regarding the Division of Examination’s process by which they select advisers for examination. The Division also included an attachment that mirrors
Investors seeking EB-5 status in the United States often turn to an attorney specializing in Immigration Law to draft the necessary petitions and disclosure documents. However, it is very important that the attorney also have an understanding of applicable securities
Investors who wish to acquire permanent residence in the United States may seek such status by applying to the United States Citizenship and Immigration Services agency (“USCIS”) for a foreign investor visa. The U.S. Congress created this immigrant visa category