Form ADV disclosures
Form ADV disclosure requirements are pressing hard on trade and geopolitical risk practices, as the U.S. Securities and Exchange Commission has made geopolitical risk exposure a live examination priority following its 2023 risk alert on adviser conflicts and third-country relationships. The SEC's Division of Examinations is scrutinizing how investment advisers characterize sanctions exposure, supply chain dependencies, and foreign government relationships in Part 2A narratives. Compliance teams are not waiting for formal guidance; many are revising their ADV filings now to align material risk descriptions with the Office of Foreign Assets Control's updated designation patterns and the Committee on Foreign Investment in the United States mitigation agreement disclosures.
Watch
- SEC Division of Examinations 2023 risk alert: adviser conflicts tied to foreign relationships
- Part 2A Item 9 language: how far does 'geopolitical risk' need to go?
- OFAC designation updates triggering retroactive ADV materiality reviews
- CFIUS mitigation agreements: disclosure obligations for registered advisers with covered transactions
- ADV amendment deadlines when a geopolitical event changes a firm's risk profile mid-year
Recent material activity in Trade & Geopolitical Risk
Active monitoring in place across Trade & Geopolitical Risk. Material developments related to form adv disclosures will appear here as they are published.