Regulatory Alerts2019-11-22
Added · Updated
Standards of conduct expected of asset managers considering dubious private fund and discretionary account arrangements or transactions
The Securities and Futures Commission requires asset managers to implement written procedures and controls to identify and assess dubious private fund and discretionary account arrangements. These procedures mandate a three-stage process involving initial screening, detailed due diligence on investors and instructions, and senior management review to ensure transactions are legitimate and properly documented. Senior management must assume responsibility for these controls and only approve such arrangements after being satisfied that concerns regarding illegitimacy or funding sources have been sufficiently addressed.
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