SEC Rule 206(4)-8
It prohibits such an investment adviser from otherwise engaging in any act, practice, or course of business that is fraudulent, deceptive or manipulative.
The SEC said the company represented to private fund investors that the firm was voluntarily complying with AML due diligence laws despite actual processes for same being used.
Julie DiMauro1 min read
The charges arise from prospectuses stating that the company would exclude ESG-negative industries from its investments.
Alexander Barzacanos2 min read
The SEC said the business also favored certain advisory clients when directing and executing cross trades, in violation of its fiduciary duty.
Julie DiMauro3 min read
Enforcement actions addressed a failure to develop a mutual fund AML programme along with misstatements in its ESG investment process.
Julie DiMauro3 min read
Defendants allegedly used funds from deceased beneficiaries’ accounts on golf tournaments and beach parties.
Thomas Hyrkiel1 min read