Robert Sawyer

3 weeks ago | delinea.com | Robert Sawyer

Privileged Access Management (PAM) is the cornerstone of cybersecurity strategy. PAM traditionally focused on IT users with elevated access, and while PAM remains core, the focus has shifted to securing all identities that have privilege, not just a small group of trusted administrators. The identity attack surface is diverse and expanding – across on-prem, cloud, and SaaS environments.

1 month ago | medium.com | Robert Sawyer

1. It would have been kinder if he had been allowed to enjoyOne more summer, one last summer. “Summertime, when the living is easy.”A few months more with which to settle his affairsTo have one last laugh before turning his back on us,On another wet and punishing fall. 2. He lived longer than any of us might have expectedAnd, died before any of us would have wanted.

Oct 23, 2024 | mondaq.com | Robert Sawyer |Jeffrey Collins |Julia Dash

Key Takeaways: The SEC adopted Rule 13f-2 and the corresponding Form SHO that requires institutional investment managers ("Managers") to report certain short position and short activity data for equity securities on a month-to-month basis if certain thresholds are met. The compliance date for Rule 13f-2 and the related Form SHO is January 2, 2025. On October 13, 2023, the SEC adopted Rule 13f-2 and related Form SHO pursuant to the Securities Exchange Act of 1934 (the "Exchange Act").

Sep 11, 2024 | mondaq.com | Adam Safwat |Aleksis Fernandez Caballero |Robert Sawyer

On August 28, 2024, the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN") issued its final rule requiring certain investment advisers to implement anti-money laundering ("AML") compliance procedures, one of the more significant recent AML regulatory developments.1 FinCEN's final rule ("the new FinCEN Rule") will require some registered investment advisers ("RIAs") as well as exempt reporting advisers ("ERAs") to develop procedures that satisfy the requirements...

Sep 9, 2024 | mondaq.com | Robert Sawyer |Ayah Zaidi

Private fund managers are reminded that the Corporate Transparency Act (CTA) may trigger reporting obligations to the Department of the Treasury's Financial Crimes Enforcement Network for private fund managers and the private funds they manage in 2024 as soon as 90 days after the initial organization of a new entity or by January 1, 2025, for existing entities (formed prior to January 1, 2024).