The firm’s attorneys design policies and procedures tailored to an investment advisor’s particular investment strategy, marketing, operations and overall business, including custody policies, compliance manuals and associated training, surveillance and annual audits and periodic testing, best execution (as well as allocation and other securities-trading-related matters), valuation, restricted lists, preparation for audits, including regulatory audits and proceedings, books and records retention, proxy voting, AML, KYC and privacy matters, advising on issues primarily relating to the SEC and FINRA guidelines encompassing the Investment Advisors Act and broker dealer regulation. We advise on related regulatory matters, such as investment advisory and broker-dealer registration, including preparation and initial filing of ADV Parts 1 and 2, as well as annual and periodic filings.

The firm also helps investment advisers and financial services clients to design, implement and monitor policies and procedures tailored to the development of investment products and services, as well as their associated marketing initiatives. The firm keeps abreast of regulatory developments, covering CFTC, FTC, SEC, FINRA, MSRB, bank and state regulatory guidelines and industry standards, such as GIPs. The firm also has attorneys who provide supervisory “Series 24 principal” services for certain clients.

The firm also has experience in the areas of compliance with domestic and international anti-bribery and anti-corruption (ABAC) laws (including the FCPA and the UK Bribery Act of 2010) and can assist clients to develop programs that include (1) the delivery or direction of a risk assessment designed to better understand potential ABAC risks; (2) tailored policies and procedures designed to reduce the risk that an improper payment will occur; (3) an implementation plan with trainings, procedures, and controls; (4) guidance or assistance with vetting third party agents, representatives, and third parties including appropriate contract protections and monitoring provisions; and (5) assistance with the complicated processes of dealing with ABAC risks in M&A and joint venture situations. In the event there is an ABAC issue, the firm can provide guidance or handle internal corporate investigations and interactions with enforcement agencies, including assistance with issues related to data privacy.

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