Vigilant Compliance Newsletter

Published on Jul 31st, 2025 |

Monthly Newsletter

In July, there were important releases including Vigilant Insights, SEC Releases, and Vigilant Shortlist Award Announcements.

Below is a brief overview of what took place in the month of June, and what is approaching for July.

Upcoming Filings:

08/07/25 – SEC Form 13G 10%
08/14/25 – AIFMD Annex IV – Fund of Funds
08/14/25 – SEC Form 13F Quarterly
08/14/25 – SEC Form 13G 5%
08/14/25 – NFA Form CTA-PR
08/29/25 – NFA CPO-PQR
08/29/25 – SEC Form PF Large Hedge Fund Update
08/29/25 – SEC Form PF Private Equity Fund Advisers Quarterly Event Reporting
08/29/25 – SEC Form N-PX
To stay up to date with the SEC Filing Deadlines in 2025, click here to view Vigilant’s Compliance Calendar.

Events & Public Appearances by Officials:

Vigilant Announcements:

Vigilant Shortlisted for Alternative Credit Compliance Award

Vigilant is thrilled to announce that we have been shortlisted for the 2025 Compliance Service of the Year Award by Alternative Credit Investor for their Alternative Credit Awards.
Alternative Credit Investor has been reporting on Alternative Credit since 2016 providing a specialized focus in this area.
Click here to view the shortlisting.

After getting the three (3) peat last year for the Hedgeweek US Awards as the Best Regulatory Advisory & Compliance Firm, Vigilant looks to make it a fourth consecutive year as we have been shortlisted as the 2025 Regulatory & Compliance Firm of the Year (Onshore) for the Hedgeweek US Awards.
Click here to view the shortlisting.

News and Alerts:

FinCEN IA AML Rule Postponed

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers (IA AML Rule) from January 1, 2026 until January 1, 2028.
For more information about the postponed rule, click here.

Vigilant Insights:

When Should an RIA Consider a Mock Examination

For SEC Registered Investment Advisers (RIAs), regulatory compliance isn’t just a box to check, it’s an ongoing responsibility that can significantly impact your firm’s reputation, operations, and longevity.
One of the most effective ways to assess your readiness and reduce the risk of regulatory deficiencies is through a Mock Examination. But when should your Firm start considering one?
Read more about key milestones and risk indicators that suggest it’s time for an RIA to consider scheduling a Mock Exam here.

SEC Releases:

RIA and CEO Charged for Fraudulent Billing

The SEC charged a Chicago RIA, and its CEO, on July 3, 2025, for charging improper fees.
The SEC alleges that the Firm charged more than $2.4 million in fees to its clients that were unauthorized and undisclosed.
Click here to learn more about the charges.

An RIA was charged on June 30, 2025,for false and misleading statements made to investors.
As the SEC continues its main goal of protecting investors and ensuring fair markets, Firms that mislead their investors about risks and conflicts of interests are likely to face penalties.
For further details, click here.

On July 11, 2025, the SEC charged a New York RIA for failing to disclose conflicts of interest, overbilling clients, and through its Former CCO and President they backdated compliance documents providing them to SEC Staff during a Compliance Examination.
Disclosure violations have been a recent trend in SEC charges as they pursue their goal of providing protection for investors.
Read more here.

The SEC charged the Former CCO and Vice President of an RIA on July 15, 2025, for modifying compliance documents requested by the SEC during an Examination.
SEC Examinations can be intimidating for compliance departments that have not properly prepared, and it is vital that compliance programs are run by experienced personnel with the proper resources.
For more information about the charges, click here.

The Vigilant Team is always happy to schedule a time to chat, feel free to contact us with any questions!