Doug Cornelius on compliance for private equity real estate
According to a story by Franco Ordonez, the United States has been selectively using its sanctions regime in Venezuela in an effort to destabilize the government. “For over a year, Diosdado Cabello, the former military commander and vice president of Venezuela’s governing United Socialist Party, escaped sanctions that hit more than 50 other Venezuelan officials, … Read more »
I found the two recent cases of insider trading to be clear violations that should be easy to spot. Matthew Brunstrum worked at a company with specific restrictions on trading the company’s stock. Yao Li worked a different company, but one that also had restrictions on trading the company’s stock. In both cases, the two … Read more »
The SEC’s complaint against Temenos Advisory, Inc. and George L. Taylor paints a very bad picture for the firm and its Chief Compliance Officer. In this case, the CCO is also the CEO, founder and majority owner of Temenos. A few years ago, the SEC had expressed an unwillingness to prosecute CCOs, except in three … Read more »
Under the Investment Advisers Act, investment advisers selecting broker-dealers for executing client trades have an obligation to seek to obtain “best execution” of those transactions. The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a new risk alert highlighting many of the most common deficiencies that the OCIE staff has cited in recent examinations of advisers’ compliance … Read more »
When I was a junior corporate lawyer, I sat in a debt training session. One of the partners mentioned LIBOR. The explanation confused me. But as a young lawyer I didn’t know very much about the workings of high finance. It turns out that the benchmark is hodgepodge of figures voluntarily submitted by banks with … Read more »
These are some of the compliance-related stories that recently caught my attention. Compliance 101: Defining a Control by Matt Kelly in Radical Compliance Last week I was speaking at an ethics and compliance event in Houston, where one of the other speakers stumped the crowd with a deceptively simple question: What is a control? After … Read more »
In 2016, the Securities and Exchange Commission opened its doors to the professional whistleblower when it first granted a whistleblower award to a company outsider. It’s becoming more lucrative. Last week the Commodity Futures Trading Commission announced an award of approximately $30 million to a whistleblower who voluntarily provided key original information that led to a successful … Read more »
Before all my music was digital and playing out of bluetooth speakers, I was a big fan of Monster Cables for connecting my audio and video equipment. Now those cables just sit in a plastic bin in the basement. I hadn’t thought about Monster Cables until the SEC has published the first “bedbug” letter on EDGAR … Read more »
These are some of the compliance-related stories that recently caught my attention. SEC Investor Advocate’s 2019 objectives include broker-dealer standards of conduct, Kokesh concerns by Amanda Maine, J.D. in Jim Hamilton’s World of Securities Regulation The SEC’s Office of the Investor Advocate (OIA) has submitted a report on its objectives for fiscal year 2019, which … Read more »
The Securities and Exchange Commission packaged together five separate settled proceedings against registered investment advisers, investment adviser representatives, and a social media consultant for violations of the Testimonial Rule the use of social media and the internet. If you get a pitch from someone to increase your firm’s presence in search results ask that person … Read more »