Compliance

Our lawyers have extensive experience in the review, development and implementation of policies and procedures designed to assure compliance with securities and other applicable laws in the U.S., the U.K. and Japan. With more than 130 lawyers in our Securities Area, we regularly handle major compliance projects for the largest and most complex financial services organizations.

We are recognized as authorities in compliance issues by both the U.S. and U.K. financial services industries and regulators. We have been appointed on numerous occasions as Independent Compliance Consultant pursuant to regulatory orders of the U.S. Securities and Exchange Commission (SEC), stock exchanges, self-regulatory organizations and state regulators.

We understand that one size does not fit all. An organization’s compliance program must reflect the unique reality of its business. A well-designed program must be adaptable to reflect actual experiences, changes in business and developments in the regulatory environment.

Experience
We regularly provide compliance consulting services to: 

  • Investment advisers registered with the SEC and/or the FSA 
  • Registered investment companies, including mutual funds, closed-end funds and variable insurance 
  • Broker-dealers
  • Transfer agents, administrators and service providers 
  • Securities exchanges
  • Proprietary investment businesses
  • Hedge funds, private equity and other unregistered funds
  • Unregistered investment advisers

Services
Our compliance services include:

  • Design and drafting of compliance programs, policies and procedures
  • Assistance with annual and other reviews
  • Testing and evaluation of compliance programs 
  • Conducting “mock” regulatory exams
  • Acting as Independent Compliance Consultant 

Areas of Advice
We routinely provide advice on a variety of compliance topics, including but not limited to:

  • Compliance with SEC, FINRA and state regulations relating to broker-dealers, investment advisers, investment companies and transfer agents 
  • Compliance with the U.K. and Japanese Financial Regulation requirements
  • Conflicts of interest
  • Personal trading
  • Information barrier/insider trading policies
  • Investment adviser code of ethics
  • Privacy and data security
  • Equity and fixed-income trading
  • Records retention
  • Registration and regulatory reporting
  • Gifts and gratuities
  • Anti-money laundering and OFAC compliance