Enforcement cases and questions for private fund advisers when considering policies and procedures reasonably designed to prevent the misuse of material, non-public information.
Registered investment advisers – even those that do not provide advice about digital assets – are increasingly becoming aware of the need to take digital assets into account when drafting and implementing their codes of ethics.
The SEC settled charges against a former chief compliance officer of a registered investment adviser for providing backdated and inaccurate information and withholding a compliance record in connection with an...
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