North America: Finance and Banking

The Cayman Islands and the British Virgin Islands (“BVI”) occupy a leading position in the global investment funds landscape.

The Securities and Exchange Commission has proposed rescinding the Investment Advisers Act's Pay-to-Play Rule in its entirety, potentially eliminating strict prohibitions on political contributions by investment advisers serving state and local government entities. While this would provide significant relief from the rule's rigid framework and severe penalties for minor violations, advisers must understand that pay-to-play compliance obligations would persist through other federal regulations, state laws, p

The SEC has proposed rescinding its 2010 pay-to-play rule that restricted political contributions by investment advisers and their employees to government officials. After nearly sixteen years of enforcement, the Commission now characterizes the rule as having "significant unintended consequences" with draconian penalties for minor violations, proposing instead to rely on existing antifraud provisions to address pay-to-play practices.