SEC Enforcement – Private Fund Custody Audit Alert

private fund custody audit

SEC Action: In July 2018, the SEC instituted administrative cease and desist proceedings resulting in a censure and a fine of $75,000 against New Silk Route Advisors, L.P. (“NSR”) for failing to send annual audited financials to its private fund investors within 120 days of its fiscal year end.[1] Background:...

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Lessons Learned from Recent Cybersecurity SEC Enforcement Action


Cybersecurity SEC Enforcement Action On 9/26/2018 the Securities and Exchange Commission charged Voya Financial Advisors, Inc. (‘VFA”), with violating the Safeguards Rule and the Identity Theft Red Flags Rule, which are designed to protect confidential customer information and protect customers from the risk of identity theft. The SEC’s Order states...

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Is Cannabis Making You Paranoid?

cannabis investing

Why, who’s asking? Many cannabis-related businesses are in need of assistance with their fundraising efforts to expand their operations. Therefore, broker-dealers ask our Consultants more and more whether they can safely provide investment services to prospective customers in the cannabis industry. We understand that as the industry grows (like a...

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Tone-Deaf at the Top

tone deaf

I recently spoke at the IA Watch/Regulatory Compliance Watch compliance conference in Philadelphia sponsored by Simplify Compliance, where the discussion turned to firms’ tone at the top. “Tone at the Top” is a term that describes a firm’s management and whether they are committed to ethical behavior, honesty, and integrity....

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