Michael Barakat
Director, Investment Adviser Compliance
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Insights & Resources
If FinCEN’s proposed rule is adopted, SEC Registered Investment Advisers and Exempt Reporting Advisers would be subject to FinCEN’s AML and CFT requirements.
The SEC staff report may lead to a revised definition which could create challenges for private funds’ investor qualification procedures and compliance program.
The SEC’s 2024 examination priorities which will focus on key risks for private funds and exam priorities for the upcoming year.
The SEC has made the first material change in beneficial owner reporting in almost 50 years with updates to Regulation 13D-G.
The SEC adopted a final rule under the Investment Advisers Act of 1940 that will greatly increase the accounting and audit requirements for private fund advisors.