CSS Blog

News, updates and analysis from around the world of compliance

AIMA Forum Takeaways: Technology, Innovation and Change

We’re still digesting all the great takeaways from the recent AIMA Global Policy & Regulatory Forum 2019. The theme was “Technology, Innovation, Change,” which is exactly what firms should be focused on this year. In the general session, Jeanette Turner, Chief Regulatory Officer of CSS, led a lively panel on “Technology as a Gamechanger” with … Continued

How to Be a Wildly Effective Compliance Officer

Being a Compliance Officer is no easy task. Administering a compliance program, implementing controls to help protect clients and the firm, and staying on top of new regulations is only part of the job. Compliance Officers are also expected to be flexible and pro-business. So how do you do it all? How can you be … Continued

Mitigating the Risk of Insider Trading

One of the biggest risks affecting investment advisers is the potential that material non-public information (“MNPI”) may be misused, leading to a charge of insider trading. Advisers should implement controls to mitigate these risks. Steven Stone of Morgan, Lewis & Bockius, LLP, Salvatore Cincinelli of the FBI and David Chaves of Tone at the Top … Continued

Compliance 2.0 – Being a Strategic Partner in Your Firm

Compliance as a profession continues to evolve. With Enron, Bernie Madoff and numerous other failures paving the way for rulemaking across industries and nations, the days of drawing a short straw, getting drafted into a compliance role and operating in isolation outside of the business are – or should be – ancient history. Since the … Continued

Big Data Part III: Preparing for the Future of Global Regulatory Governance

United States and European Union reporting requirements imposed on investment managers have exploded since the Global Financial Crisis and, with the imminent arrival of SFTR in Europe, it seems poised to expand again. The challenge of reporting trades, transactions and contracts in multiple jurisdictions requires firms to embrace technology as regulators continue to look to … Continued

Custody Concerns Continue

You timely filed your Form ADV within 90 days of fiscal year end, but, did you properly answer all the questions related to custody? Not surprisingly, the Form remains confusing for many advisers, as does application of the Custody Rule itself. The SEC has issued guidance, letters to the industry, alerts and FAQs, but things … Continued

Blockchain Isn’t Hot Sauce

Guest post by Samson Williams, Partner – Axes & Eggs and Keynote Speaker – Ascendant CSS Spring 2019 Conference  I started telling people that blockchain isn’t hot sauce in mid-2017 to help explain why initial coin offerings (ICOs) were just the latest form of unregulated, online gambling. In November 2017, with Bitcoin nearing a high … Continued

ESMA Updates AIFMD Q&As

The European Securities and Markets Authority (ESMA) has updated its Questions and Answers on the application of the Alternative Investment Fund Managers Directive (AIFMD). Specifically, ESMA has added two new Q&As, providing clarification on the calculation of leverage under AIFMD: The treatment of short-term interest rate futures for the purposes of AIFMD leverage exposure calculations … Continued

Regulation Best Interest, Cybersecurity Top Concerns at IAA 2019 Compliance Conference

The Investment Adviser Association (IAA) represents the interests of investment advisers in Washington D.C., and the IAA Investment Adviser Compliance Conference 2019 was a forum for the discussion of future potential rulemaking. Cybersecurity and Fiduciary Rule considerations were headline topics, with custody and marketing right behind. The following is a summary of key issues discussed … Continued

Shareholder Monitoring and Disclosures: Keeping One Step Ahead of the Front Office

Fresh from our London conference “Looking at the Year Ahead – Global Compliance and Data Priorities” – a rousing success! – we’ll cover takeaways from a key panel discussion on shareholder monitoring and disclosures. Two of the best in the business were in the house (or should we say “in the brewery,” an amazing London … Continued

The Challenges of Building a Global Compliance Program

Compliance programs face challenges in balancing global requirements with local exceptions while incorporating the fast pace of regulatory change, addressing critical business needs and obtaining the necessary resources necessary to manage the program. Trends and thinking on the subject were center stage at the recent CSS London event “Looking at the Year Ahead – Global … Continued

Coming to America – California Adopts GDPR-Like Privacy Regulation

After a number of firms struggled last year to get their marketing and information systems into compliance with the EU’s General Data Protection Regulation (GDPR), advisers to U.S. clients will soon be facing similar requirements on the home front. On the heels of the Cambridge Analytica scandal, California enacted the California Consumer Privacy Act of … Continued

An Overview of MMFR – Article 37 Reporting Requirements

The European Union’s Money Market Funds Regulation (MMFR) applies to any Money Market Fund (MMF) that is authorized as a collective investment scheme under either the Undertakings for the Collective Investment in Transferable Securities Directive (UCITS) or the Alternative Investment Fund Managers Directive (AIFMD). Managers subject to UCITS or AIFMD will continue to be regulated … Continued

SEC Reopened After 35-Day Government Shutdown

SEC Chairman Jay Clayton announced on Saturday, January 26 that with an agreement reached to end the government shutdown, the “Commission has resumed normal staffing levels and is returning to normal operations.” In total, about 94% of the commission’s approximately 4,400 employees had been furloughed during the 35-day shutdown, according to its operations plan. In a … Continued


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CSS frequently publishes blog posts which are written by our team from their observations in the field, at conferences and through experiences with compliance professionals. These posts are designed to further knowledge and share industry best practices. Topics run the gamut, including Form ADV, cybersecurity, MiFID II, position limit monitoring, technology challenges and more. Complete and submit the brief form below to receive notifications when we publish new content.

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