The Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) released a “Risk Alert” on November 9, 2015, the purpose of which is to raise awareness of compliance issues observed in connection with the examination of registered investment advisers and investment companies that outsource their Chief Compliance…
On February 3, 2015, the Securities and Exchange Commission (“SEC”) released two publications addressing cybersecurity at advisory and brokerage firms. The first publication, a Risk Alert, relays the findings from the examinations of more than 100 investment advisers and broker-dealers and focuses on how they: (i) establish cybersecurity policies, procedures…
By William M. Sullivan, Jr. and Jay B. Gould Under the Second Circuit’s new ruling, prosecutors have two large hurdles they must clear to convict under securities laws. First, they must prove that a defendant knew that the source of inside information disclosed tips in exchange for a personal benefit.…