Fraud Torn Paper Concept

The One With The Floundering Hedge Fund

I’m a local homer, so fraud cases in Massachusetts catch my attention, especially when they involve private funds. The case of the floundering hedge fund, MC2 Capital, founded by Yasuna Murakami, is the usual example of greed and failure to acknowledge one’s mistakes. Mr. Murakami had big dreams and in the glory days of 2007 thought […]

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Compliance Bricks and Mortar for May 19

These are some of the compliance-related stories that recently caught my attention. Cybersecurity: Ransomware Alert from SEC’s OCIE Starting on May 12, 2017, a widespread ransomware attack, known as WannaCry, WCry, or Wanna Decryptor, rapidly affected numerous organizations across over one hundred countries. Initial reports indicate that the hacker or hacking group behind the attack […]

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The SEC Reaching Back Far In The Past With Its Powers of Disgorgement

We have become used to the Securities and Exchange Commission extracting disgorgement of ill-gotten gains from those violating the securities laws. However, the enabling laws do not explicitly grant the SEC the right to disgorgement. We seem to accept that power, but how far back can the SEC go to grab cash from defendants? In […]

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I’m Once Again Asking You For Your Hard-Earned Money

Compliance Building is a free resource I publish for me, and share with you, to help the compliance profession. Now I need some of your hard-earned money. I should point out that the money is not for me; It’s for charity. Help me fight cancer, by raising money for the Dana Farber Cancer Institute. I’m riding the […]

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insider trading

The One With The Pilfering Lawyer and The Document Management System

The SEC and the DOJ broght charges against Walter C. Little and his neighbor Andrew M. Berke for illegal insider trading. This particular case caught my attention because Mr. Little was a law firm partner and he found the information by searching through his law firm’s document management system. According to the complaints, Mr. Little […]

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We Have Seen The Enemy And It Is US

There was a massive cyberattack over the weekend that has afflicted 200,000 computers in more than 150 countries. The malware locks users out of their computers and threatens to destroy data if a ransom is not paid. It turns out that the the malicious software used in the cyberattack was originally been developed by the […]

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The Jay Clayton Era at the SEC Has Begun

Jay Clayton was sworn in last week as the new Chairman of the Securities and Exchange Commission. That makes him the first permanent head of a financial regulator during the Trump administration. Yesterday, Chairman Clayton gave his first public speech by making the opening remarks at the SEC Advisory Committee on Small and Emerging Companies. […]

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Comey and Compliance

The firing of FBI Director has set off a firestorm. Obviously, there is a great deal of partisan tilt to the action. I wanted to focus on the lesson we can see from a compliance perspective. It is an example of the need for independence of compliance and investigations. President Trump fired someone who was […]

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Real Estate Fund Information from the SEC

The Securities and Exchange Commission has been acquiring troves of data about private funds through the Form PF filing requirement. Some, including myself, have been skeptical that the SEC will figure out what to do with the data as a tool to protect investors. But, the SEC has been able to compile statistics and published a […]

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bourbon empire

Weekend Reading: Bourbon Empire

I went on Spring vacation to Kentucky with Mrs. Doug and the compliance nuggets. There was a lot of bourbon and horses. For vacation reading, I dug into my ever-growing tower of books to read and brought along Bourbon Empire by Reid Mitenbuler to read. It seemed appropriate. Reid Mitenbuler portrays bourbon as a balance of […]

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