On March 15, 2019, the U.S. Securities and Exchange Commission charged a private fund manager and its former chief operating officer with manipulating the price of an asset sold by one client to another. The SEC’s orders charge Talimco LLC and its former Chief Operating Officer Grant Rogers with breaching their fiduciary duties in violation of the anti‑fraud provisions of the Investment Advisers Act of 1940. This action exemplifies the SEC’s continued focus on cross trades and on internal controls relating to conflicts of interest.

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