Blog
SEC Office of Compliance Inspections and Examinations (“OCIE”) Issues Alert on Cross-Trades Under Investment Advisers Act
On September 4, 2019, the OCIE issued a Risk Alert on issues identified by the staff during audits of firms of cross-trades that violate the applicable rules. Section 206(3) of the Investment Advisers Act effectively prohibits an adviser, acting as a principal or agent, from carrying out certain cross trades that would be the result... Read more »
N.Y. Department of Financial Services Grants More Cryptocurrency Licenses
On July 15, 2019, the N.Y. Department of Financial Services (the “DFS”) announced that it granted virtual currency licenses to two subsidiaries of Seed CX Ltd. as part of its supervisory authority under the so-called “Bitlicense Law“, bringing the total to four since DFS Superintendent Linda Lacewell became head in February. Seed Digital Commodities Market... Read more »
EU GDPR Shows Teeth
In case one got the impression that the EU’s General Data Protection Regulation (the “GDPR”) was toothless, the U.K.’s Information Commissioner’s Office (the “ICO”) announced on July 9, 2019 that it would fine Marriott International over 99 million pounds ($124 million). The fine is in relation to a 2018 breach for failing to examine and... Read more »
SEC Issues Concept Release on Private Placements
On June 18, 2019, the Securities and Exchange Commission (the “SEC”) issued a more than 200-page concept release about ways to simplify, improve and harmonize exempt offerings, including private placements, Regulation Crowdfunding and others. The SEC raises numerous issues for comment, such as, for example, whether and how the “accredited investor” definition should be changed,... Read more »