Claudette Druehl

2 months ago | jdsupra.com | Joel Cohen |Claudette Druehl |Jason Ho

The U.S. Securities & Exchange Commission ("SEC") recently announced settled charges against an investment adviser for misrepresentations regarding its anti-money laundering ("AML") procedures and compliance failures.1 As we outlined in our recent client alert, investment advisers will be required by the Financial Crimes Enforcement Network ("FinCEN") to implement an AML program by January 1, 2026. This SEC action does not shed new light on the scope of SEC jurisdiction over AML.

Nov 14, 2024 | jdsupra.com | Claudette Druehl |Tami Stark

On October 21, 2024, the US Securities and Exchange Commission ("SEC") Division of Examinations ("Examination Division") announced its 2025 Examination Priorities ("Report").1 Investment advisers and broker-dealers should ensure that policies, procedures and surveillance efforts related to these priorities address concerns outlined in the Report. The Examination Division conducts inspections of entities registered with the SEC, including investment advisers and broker-dealers.

Sep 16, 2024 | lexology.com | Joel Cohen |Marietou Diouf |Tami Stark |Pratin Vallabhaneni |Claudette Druehl |Robert J. DeNault

On August 28, 2024, FinCEN issued a long-awaited final rule meant to address illicit finance activities and national security threats in the asset management industry. The new rule imposes similar requirements on investment advisers that have existed for broker-dealers since 2001 and ends a period of uncertainty for registrants in this area.

Sep 10, 2024 | corpgov.law.harvard.edu | Tami Stark |Claudette Druehl |Robert J. DeNault

Advisers Act, Civil Penalties, Exchange Act, SEC, self-disclosureMore from: Claudette Druehl, Robert DeNault, Tami Stark, White & CaseTami Stark is a Partner, Claudette Druehl is a Counsel, and Robert DeNault is an Associate at White & Case LLP. This post is based on their White & Case memorandum.

Aug 29, 2024 | jdsupra.com | Robert J. DeNault |Claudette Druehl |Tami Stark

On August 14, the U.S. Securities and Exchange Commission (“SEC”) announced yet another wave of enforcement actions related to widespread “off-channel communications,” charging an additional 26 firms with failing to maintain employee communications on personal devices which related to the firms’ business.1 The new settlements add nearly $400 million to the billions in civil penalties that the SEC has collected from more than 50 firms over the last few years for recordkeeping failures related...