Enforcement cases and questions for private fund advisers when considering policies and procedures reasonably designed to prevent the misuse of material, non-public information.
September 22, 2022
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SEC Risk Alert Focuses on MNPI and Code of Ethics Compliance Issues
The SEC has issued a risk alert on MNPI and Codes of Ethics.
April 28, 2022
SEC Charges Quantitative Analyst in Front-Running Scheme
The SEC has charged a quantitative analyst in a front-running scheme the SEC claims resulted in over $8.5 million in trading profits.
October 06, 2021
Use of Alternative Data by Investment Advisers
The search for “alpha” by investment advisers has led to new ways to capture and utilize data in the investment decision-making process. Many advisers believe that incorporating alternative data, which...
July 20, 2021
SEC’s Gensler Questions Executive Stock Ownership Plans
SEC Chair Gary Gensler Pointing to “real cracks in our insider trading regime,” SEC Chair Gary Gensler told a Chief Financial Officers forum on June 7 that he’s asked...
June 09, 2021
SEC Enforcement Breaks Records for Total Disgorgement, Penalties, and Whistleblower Awards
The SEC’s Division of Enforcement’s 2020 annual report shows a record in total monetary remedies during the fiscal year (FY) ended September 30, 2020 of $4.680 billion, as compared to...
November 05, 2020
12 Practical Tips for Advisers on Insider Trading Issues
Insider trading is a top priority of the SEC’s inspection and enforcement programs. In light of this, advisory firms should note the following: Investment advisers are required to adopt policies...
October 20, 2020
Second Circuit Insider Trading Decision Likely to Make Criminal Convictions Easier
Second Circuit Insider Trading Decision Likely to Make Criminal Convictions Easier January 17, 2020 The Second Circuit issued an opinion in United States v. Blaszczak (Dec. 30, 2019), affirming wire fraud,...
January 17, 2020