DOL, SEC Cybersecurity Regulations: Divergence or Convergence?

The temperature is rising on the quality of cybersecurity risk for registered investment advisors, whether they are in the DOL space or not. In February, the U.S. Securities and Exchange Commission voted to propose two new rules on cybersecurity: rule 206(4)-9 under the Advisers Act and rule 38a-2 under the Investment Company Act. From a high-level perspective, … Read more

FinCEN Issues Advisory on Kleptocracy and Foreign Public Corruption

The Financial Crimes Enforcement Network (FinCEN) today issued an advisory on kleptocracy and foreign public corruption, urging financial institutions to focus their efforts on detecting the proceeds of foreign public corruption—a priority for the U.S. Government as it continues to implement the U.S. Strategy on Countering Corruption. The advisory provides typologies and potential indicators of kleptocracy and … Read more

The Benefits of Implementing Investigative Due Diligence Research to an Organization’s Supply Chain Vendor Management Program Initiatives

Most organizations that will be making strategic and critical business decisions, it is imperative to undertake an extensive due diligence investigation. Due Diligence is defined as, “the care a reasonable person exercises to avoid harm to other persons or their property.” Investigative Due Diligence refers to the research and analysis of an individual or organization done … Read more

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