On 24 November 2015, the US SEC announced that it had accepted an offer of settlement from Marwood Group Research LLC (Marwood), a New York City-based regulatory and legislative policy firm, in relation to breaches of the Securities Exchange Act 1934 and the Investment Advisers Act 1940.

The above acts impose obligations on companies to “establish, maintain, and enforce written policies and procedures… to prevent the misuse” of material non-public information. However, the SEC found that, although Marwood had policies in place, they were not “reasonably tailored” to its business and, in any case, were not enforced.

Marwood was ordered to pay $375,000 in penalties, and to retain a compliance consultant to conduct a review of its compliance policies and procedures.