An investment adviser posts a seemingly innocuous comment to his firm’s social networking profile page, congratulating his colleagues on a successful year selecting investments. Another adviser, upon realizing that one of her long-time clients has recently moved and did not receive the firm’s new Form ADV brochure, quickly sends an e-mail to the client and attaches the requested documents.
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Past Conference Speaker Inspiration for The Rock’s Next Blockbuster
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 … Continued
Relief at Last – New Guidance on Inadvertent Custody
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 … Continued
Advisers Beware: FBI “Operation WireWire” Shows Firms Increasingly Being Targeted Using SEC Filings
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 … Continued
Deputy Attorney General Rod Rosenstein Discusses Compliance Program Effectiveness
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 … Continued
Cayman Islands Update AML Regulations for Private Equity
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 … Continued
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