Blog – Ascendant Compliance https://www.ascendantcompliance.com Ascendant Compliance Management is a leader in the compliance and regulatory services industry, offering personalized, comprehensive compliance services for firms in the U.S. and abroad. Thu, 21 Jun 2018 20:13:54 +0000 en-US hourly 1 Past Conference Speaker Inspiration for The Rock’s Next Blockbuster https://www.ascendantcompliance.com/blogs/past-conference-speaker-inspiration-for-the-rocks-next-blockbuster/ Tue, 19 Jun 2018 15:34:53 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3800 Continued]]> If you attended Ascendant’s 2016 San Diego conference,  you will no doubt remember our outstanding keynote speaker, Jeff Glasbrenner. Jeff is a below-the-knee amputee who was fresh off becoming the first American amputee ever to scale Mount Everest. In San Diego, he spoke about turning challenges into triumphs, and about succeeding in the face of adversity. His message wasn’t just an...

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Relief at Last – New Guidance on Inadvertent Custody https://www.ascendantcompliance.com/blogs/relief-at-last-new-guidance-on-inadvertent-custody/ Fri, 15 Jun 2018 15:41:36 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3780 Continued]]> The SEC quietly provided additional guidance to the industry about inadvertent custody in supplemental responses to the Custody Rule FAQs. In Question II.11 and II.12, the SEC stated that it would not recommend enforcement against an adviser that does not have a copy of a client’s custodial agreement, and does not know or have reason to know whether the client’s custody agreement would give the...

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Advisers Beware: FBI “Operation WireWire” Shows Firms Increasingly Being Targeted Using SEC Filings https://www.ascendantcompliance.com/blogs/advisers-beware-fbi-operation-wirewire-shows-firms-increasingly-being-targeted-using-sec-filings/ Thu, 14 Jun 2018 15:41:32 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3774 Continued]]> Ascendant has observed more and more investment advisers falling victim to Business Email Compromise, or “BEC” schemes over the past year. Unfortunately, they are in good company, as the trend is consistent with a worldwide increase in such attacks by increasingly skilled hacker networks around the world. On June 10, 2018, the FBI announced in a press release that it had coordinated...

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Deputy Attorney General Rod Rosenstein Discusses Compliance Program Effectiveness https://www.ascendantcompliance.com/blogs/deputy-attorney-general-rod-rosenstein-speaks-at-compliance-conference/ Fri, 01 Jun 2018 15:55:30 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3739 Continued]]> The embattled U.S. Deputy Attorney General Rod Rosenstein recently spoke to compliance pros at the 2018 Annual Conference for Compliance and Risk Professionals.  Bulleted below are some of the statements from his keynote speech, which evidence the view from near the top of the Department of Justice: As to what it means to have a culture of compliance, he gave details: “Employees should be trained...

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Cayman Islands Update AML Regulations for Private Equity https://www.ascendantcompliance.com/blogs/cayman-islands-update-aml-regulations-for-private-equity/ Mon, 21 May 2018 13:00:37 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3706 Continued]]> The Cayman Islands has further bolstered its anti-money laundering (“AML”) and countering of terrorist financing (“CTF”) rules. The new AML/CTF rules become effective on May 31, 2018 and will affect, among others, unregulated investment entities—such as private equity firms—domiciled in the Cayman Islands. The deadline to appoint AML officers, however, is September 30, 2018 for existing funds and...

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SEC Creates Bogus ICO Site to Teach About Cryptocurrency Fraud https://www.ascendantcompliance.com/blogs/sec-creates-bogus-ico-site-to-teach-about-cryptocurrency-fraud/ Fri, 18 May 2018 19:05:22 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3702 Continued]]> On May 16, 2018, the SEC’s Office of Investor Education and Advocacy launched an educational website meant to demonstrate a fraudulent initial coin offering (ICO). The website, HoweyCoins.com mimics a bogus coin offering touting a too-good-to-be-true investment opportunity. The website features several of the features common to fraudulent offerings, including promises of guaranteed returns...

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Get ready for Form ADV, Part 3: Form CRS https://www.ascendantcompliance.com/blogs/get-ready-for-form-adv-part-3-form-crs/ Tue, 15 May 2018 18:30:57 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3695 Continued]]> Are you ready for Form ADV Part 3? As if the last annual updating amendment filing was not tedious enough with all the additional information related to separately managed accounts, the process will further evolve with the SEC’s proposal for a Form ADV Part 3, also referred to as Form CRS. But don’t worry, it can only be four pages in length! You will now be required to provide retail...

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For Cryptocurrency and Blockchain, a Reckoning is Coming https://www.ascendantcompliance.com/blogs/for-cryptocurrency-and-blockchain-a-reckoning-is-coming/ Wed, 09 May 2018 14:30:07 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3687 Continued]]>  NOTE: Ascendant Director of Cyber IT Services E.J. Yerzak recently spoke at the AIM Summit in Abu Dhabi, a conference that targets alternative investment managers. The following is a brief summary of his key comments during his two sessions, “Primer on Crypto Currency, Distributed Ledger Technology and ICO’s,” and “Legal & Regulatory Insights/AML – Blockchain” E.J. Yerzak in Abu Dhabi...

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Code of Ethics: SEC Focus Shifts Radar to Retail Firms https://www.ascendantcompliance.com/blogs/code-of-ethics-sec-focus-shifts-radar-to-retail-firms/ Mon, 07 May 2018 19:22:05 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3674 Continued]]> Each investment adviser’s Code of Ethics and other compliance policies set forth the standards of business conduct to which supervised persons must adhere. The challenge can often be monitoring compliance with the policies and assisting supervised persons with understanding their responsibilities. CCOs should put themselves in the SEC’s position – review your Code of Ethics...

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Ascendant’s Melanie Mendoza Authors Due Diligence Journal Article https://www.ascendantcompliance.com/blogs/ascendants-melanie-mendoza-authors-due-diligence-journal-article/ Thu, 03 May 2018 15:06:23 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3666 Continued]]> Ascendant Senior Consultant Melanie Mendoza has over 30 years of investment compliance industry experience, focused on investment advisers, registered investment companies and private investment funds. That experience came to great use when Wolters Kluwer asked her to cover the top topic of due diligence for Practical Compliance & Risk Management For the Securities Industry, a journal written...

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