In today’s edition of Daily Compliance News:
Tag: crypto
Digital Assets: Trading & Compliance for Cryptocurrency
In this episode, Director of Registered Investment Company Services, Allison Fraser and Director of Broker-Dealer Services & Private Funds, John Gentile discuss the latest on digital assets and cryptocurrency. Are they considered securities, what does the SEC’s risk alert mean for digital assets, and how should investment managers be thinking about cryptocurrency trading and compliance?
About Our Guest Speakers:
Allison Fraser provides compliance consulting services to investment advisers, registered investment companies and private investment funds, including conducting annual compliance program reviews and testing, developing risk assessments and preparing for SEC examinations. She also assists clients with drafting policies and procedures and preparing regulatory filings. On behalf of, the Compliance Services division of CSS, Allison served as the Chief Compliance Officer for a family of alternative funds registered under the Investment Company Act of 1940. Prior to joining CSS, Allison served as a Senior Vice President of Compliance at Northern Trust Investments, Inc. (“NTI”), the asset management subsidiary of The Northern Trust Company. In this capacity, she managed and administered the compliance due diligence program for NTI’s Multi-Manager Solutions and Outsourced Chief Investment Officer businesses. Allison also was the Chief Compliance Officer of two registered funds of hedge funds advised by NTI as well as a member of the funds’ Pricing and Disclosure Committees. Before joining NTI, Allison served as the Compliance Director for General Motors Asset Management, where she assisted with the administration of the compliance program for this registered investment adviser.
John Gentile is responsible for overseeing various types of broker-dealer and investment adviser consulting engagements, including conducting SEC/FINRA internal control reviews, anti-money laundering testing, written supervisory policy and procedures testing, and other consultation services. John is a frequent speaker at industry conferences on various compliance topics, including “Effective Supervision,” “Large Firm Testing,” FINRA Supervisory Control Rules” and “Anti Money Laundering Requirements for Broker Dealers under the PATRIOT Act.” In 1987 John joined the SEC as a Securities Compliance Examiner, becoming a Branch Chief in 1991. He became Assistant Regional Director in 1993, supervising a team of 20 broker-dealer managers and examiners. He also planned and conducted financial, operational, and sales practice examinations of the largest broker dealers and was among those responsible for a review of hedge funds’ impact on broker dealer internal controls. Before joining the SEC, John was a Financial Damage Analyst with PaineWebber Inc. Most recently from 2000-2007 John was an Executive Consultant, Broker-Dealer Services, at National Regulatory Services. John has an MBA from Fordham University and a BS in Finance from Central Connecticut State University. From 1995 to 2002, John was also a member of the Securities Industry Continuing Education East Coast Content Committee.
Categories
The Mood of Compliance
The Mood of Compliance
In this episode, CSS’s Executive Director, Jackie Hallihan and Senior Consultant, Adam DiPaolo discuss observations on the mood of compliance, with predictions of heavy regulatory activity, and key areas of focus including enforcement, ESG, cryptocurrency, whistleblowers and cybersecurity.
About Our Guest Speakers:
Jackie Hallihan is the Co-Executive Director of CSS’s Compliance Services team and has over 25 years’ regulatory and risk management experience. She was the founder of National Regulatory Services (NRS) which started the compliance resource business and served as its President for over 20 years. She also founded the National Society of Compliance Professionals (NSCP), a non-profit organization for compliance officers, staff and lawyers serving the compliance industry. It now boasts over 2000 memberships. Jackie has been a leading speaker to compliance professionals, including in-house training programs and various other industry association conferences, and has received numerous industry awards. Jackie also serves as Director, Clerk of the New England Broker Dealer Investment Adviser Association (NEBDIAA), a non-profit organization, incorporated in 1997. The purpose of NEBDIAA is to provide a forum for the professional exchange of information among investment advisers, broker dealers, and persons who provide services to investment advisers and broker dealers, and to direct communication among its members which will improve their ability to serve the needs of their respective clients. The forum will help NEBDIAA’s members meet the increased regulatory demands placed on investment advisers, broker dealers, and persons who provide services to investment advisers and broker-dealers.
Adam DiPaolo CISA, CRISC is a Section 13 Reporting Manager, Senior Consultant and Associate General Counsel at CSS. Adam designs practical solutions to manage regulatory challenges faced by hedge funds, private equity funds, funds of funds, and other investment advisers. In addition to providing compliance services such as annual compliance program reviews, risk assessments and acquisition due diligence, Adam established Section 13 reporting capabilities and EDGAR filing agent services for CSS’s Compliance Services division. He drafts and maintains corporate filings ranging from Forms ADV and PF to Forms 13F and 13H. Adam also provides cybersecurity risk management services to CSS clients – ranging from network vulnerability scanning to onsite cybersecurity risk assessments to assistance in implementing the NIST cybersecurity framework. He is a Certified Information Systems Auditor (CISA®), and Certified in Risk and Information Systems Control (CRISC™). Adam practiced corporate law prior to joining CSS and has an extensive background in both the public and private sectors. Adam served as Assistant General Counsel at Capgemini – one of the world’s largest providers of Consulting, Technology and Outsourcing services. As in-house counsel to a global consulting business, he implemented pragmatic strategies to resolve complex legal and regulatory issues. Adam earned his B.A. from Pitzer College, his J.D. degree from UC Berkeley – Boalt Hall School of Law, and his LL.M. in Taxation from New York University School of Law. He is a member of the New York State Bar.
In today’s edition of Daily Compliance News:
- SEC announces SPAC enforcement action. (SEC Press Release)
- Banking regulators seek comments on 3rd risk management. (WSJ)
- Swiss arrest German attorney in tax fraud case. (GAN Newsletter)
- Is crypto legit? (NYT)
Betting on Bitcoin: Cryptocurrency & Digital Assets 101 for Investment Managers
In this episode, CSS’s Director of Broker-Dealer Services and Private Funds John Gentile sits down with Chief Executive Officer & Chief Investment Officer of Off the Chain Capital, Brian Estes to discuss the world of cryptocurrency and Bitcoin. Is this investing or gambling, is it an asset class, and why should investment advisers and broker-dealers be thinking about adding digital assets to their clients’ portfolios?
About Our Guest Speakers:
John Gentile is responsible for overseeing various types of broker-dealer and investment adviser consulting engagements, including conducting SEC/FINRA internal control reviews, anti-money laundering testing, written supervisory policy and procedures testing, and other consultation services. John is a frequent speaker at industry conferences on various compliance topics, including “Effective Supervision,” “Large Firm Testing,” FINRA Supervisory Control Rules” and “Anti Money Laundering Requirements for Broker Dealers under the PATRIOT Act.” In 1987 John joined the SEC as a Securities Compliance Examiner, becoming a Branch Chief in 1991. He became Assistant Regional Director in 1993, supervising a team of 20 broker-dealer managers and examiners. He also planned and conducted financial, operational, and sales practice examinations of the largest broker dealers and was among those responsible for a review of hedge funds’ impact on broker dealer internal controls. Before joining the SEC, John was a Financial Damage Analyst with PaineWebber Inc. Most recently from 2000-2007 John was an Executive Consultant, Broker-Dealer Services, at National Regulatory Services. John has an MBA from Fordham University and a BS in Finance from Central Connecticut State University. From 1995 to 2002, John was also a member of the Securities Industry Continuing Education East Coast Content Committee.
Brian Estes is the CEO and CIO of Off the Chain Capital which manages the #1 performing blockchain investment fund over the past 4 years. Brian has been a VC in blockchain for over 7 years and has advised, mentored and/or financed 5 blockchain companies that have a combined value of over $100B today. Prior to his immersion in blockchain, the Brian was one of the top-ranked investment managers in the nation. Morningstar ranked his client’s performance between 2004-2014 in the top 1/10th of 1% of the Morningstar equity manager universe. Brian earned his BA in Economics from the University of Illinois, his MBA with high honors from Washington University, and has studied at Cambridge University and the London School of Economics. For fun, Brian earned his pilot’s license in 1989 and has logged over 2200 hours of flight time in his Cessna 177RG.
