Doug Cornelius on compliance for private equity real estate
Early this year when the US invaded Venezuela and captured Venezuelan leader Nicolás Maduro there was a series of well timed trades on the Polymarket prediction market. “Predictios” purchases of $32,000 were placed from December 27 to January 2, just before the US military effort. Was it insider trading? No. Polymarket trades are not securities….
The prediction market platforms, Kalshi and Polymarkets have exploded this year. In some cases, for bad reasons: Federal prosecutors are exploring whether prediction market bets trip insider trading laws. The markets are not supposed to be taking predictions on the movements of securities. That would make them a derivative of a security and subject to…
Would you invest in a company that beat the S&P 500 with 19% returns over the last five years? Sounds interesting, sure… But what if the chart of performance looked like this: That is a really straight line. Just one little flat period in December 2022. No, thank you. That’s a fraud. I saw this…
It caught my by surprise that the Securities and Exchange Commission brought a case against a crypto-crap company this week. After the SEC published its “clarification” on the application of federal securities laws to crypto assets I thought we wouldn’t see a crypto case for a long time. I guess the SEC found the actions…
The other half of the Securities and Exchange Commission budget request for 2027 is a report on its performance in fiscal year 2025. How did the SEC perform in enforcement actions? The SEC was off its game. The 85% metric was the lowest in years. I believe this number might dip some more with the…
I wrote last week how the Securities and Exchange Commission had 18% of its staff depart in fiscal year 2025 thanks to the DOGE efforts to reduce the size of the federal workforce. For Fiscal Year 2027, the SEC is proposing to reduce its budget by another 11%. However, the SEC is proposing to add…
This is press release that would not have been written by judge Margaret Ryan if she was still serving as the Director of Enforcement. She only lasted six months with the rapid down-sizing and lack of enforcement at the Securities and Exchange Commission. I was stunned to see the SEC attack its prior stewardship in…
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network issued a proposed rule intended to “fundamentally reform” financial institutions’ anti-money laundering and countering the financing of terrorism programs under the Bank Secrecy Act. The three key changes according to FinCEN: Those all sound more like goals than changes. It doesn’t tell us what the…
A trucking company is looking for capital. It needs trailers and trucks. You give the company money to buy the truck on your behalf and the trucking company leases it back to you. The truck company will arrange the purchase and financing. It will find a driver. It will take care of licensing, registration, insurance,…
You’re senior management of a public company. You just made a million dollar bonus for performance. You get paid $735,000 if the company is sold. You’ve got 150,000 shares of company stock that’ll be worth over $4 million. You’re in the process of selling the company. Do you tell your wife and best friend about…