
Reut N. Samuels
Associate
Reut is an associate in the Litigation Department and a member of the Antitrust Practice and Asset Management Groups. During her time at the firm, she spent a five-month secondment working pro bono for the City of New York in the Torts Division, Special Litigation Unit.
Reut earned her J.D. from New York University School of Law and her B.S. from Cornell University. During law school, she worked at the US Attorney's Office, Criminal Division in the Southern District of New York, as well as at the Manhattan District Attorney's Office. Reut served as an Articles Editor for the Journal of Legislation and Public Policy.
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On November 4, 2022, compliance with amended Rule 206(4)-1 (the “Marketing Rule”) became mandatory for all investment advisers registered with the Securities and Exchange Commission (the “SEC”).[1] Seven months since the compliance date, SEC-registered investment advisers continue to discover and adapt to challenges in applying the Marketing Rule. Newly formed advisers also face significant obstacles … Continue Reading
Recent enforcement actions highlight the increased regulatory scrutiny that private funds may face with respect to internal cybersecurity protocols and responses to cyber-crimes and cyber incidents under new and updated cybersecurity laws. … Continue Reading
As IPOs and other traditional paths to liquidity for private assets have become more challenging, GP-led secondary transactions have emerged as a powerful and popular tool across closed-end private funds, leading to explosive growth over the last five years. And while macro factors influence their prevalence year over year, these transactions remain broadly popular across the … Continue Reading
Go to any private equity event in the last 12 months, and “energy transition” will have been discussed, meaning the shift in energy production away from fossil‑based systems to low or zero carbon ones. As fund managers continue to raise funds focused on investments in this sector, we see no reason for this trend to … Continue Reading
It’s a pattern we often see in boom-and-bust cycles—disputes rising in the period after a wave crests. SPAC deal volume hit an unprecedented high in 2021, but then slowed down in 2022 alongside IPOs. However, the fallout from the SPAC wave will continue to unfold this year, generating increased regulatory attention and a growing number of … Continue Reading
The SEC’s Enforcement Division is conducting a sweep investigation of large investment advisers regarding their employees’ use of “off-channel” communications. The sweep, which has been widely reported in the press, focuses on text messages from personal phones, personal email, WhatsApp and other platforms not typically captured or monitored by advisers. The sweep is causing considerable … Continue Reading
Implications of SEC attempt to curb indemnification for private fund managers The SEC spent 2022 making multiple and sweeping proposals to amend rules under the Advisers Act, many of which have the ability to significantly re-shape market standards for private funds. Here, we focus on the SEC’s proposal to undo a common protection for private … Continue Reading
Amid rising interest rates, tightening credit markets, geopolitical concerns in Europe and Asia, stubborn inflation and continuing supply chain issues, there is a growing sense of economic uncertainty. This uncertainty will no doubt increase the frequency of valuation disputes in the year ahead. We generally see valuation disputes spring from four primary sources: Valuation disputes … Continue Reading
Crypto firm bankruptcies and resulting disruption in the crypto ecosystem will continue to exacerbate liquidity and regulatory concerns in this space. Signs of contagion are evident as prices of almost every cryptocurrency type have halved in recent months. Since all participants supporting the crypto ecosystem are at risk, managing that risk is critical.… Continue Reading
Everything, everywhere, all at once is our risk thesis for 2023, but one must not forget about concentration risk. This issue has rocketed up diligence agendas for LPs and GPs alike as the collapse of Silicon Valley Bank proved it really was the bank for venture capital.The entry of SVB into receivership on March 10, 2023 highlighted just … Continue Reading
Everything, everywhere, all at once, as a descriptor, captures the litigation and regulatory risks for the asset management industry in 2023. Every corner of the market faces greater risks than at any time since 2008. After years of breakneck growth fueled by low interest rates and a largely laissez faire regulatory regime, significant change is … Continue Reading
As our other Top Ten posts have demonstrated, there is no shortage of risks for private fund sponsors to navigate in today’s economic and regulatory environment. Nevertheless, they need to prioritize the risk that hits closest to home – lawsuits by private litigants seeking to pull sponsors, their funds, and their board director designees into … Continue Reading
The SEC last month proposed rules under the Advisers Act indicating a dramatic shift in how the SEC intends to reduce conflicts of interest involving private fund managers and their investors. As we previously noted in the context of increased disclosure obligations, the SEC’s recent approach previews a sea change redefining the relationship between private … Continue Reading
Last month, the SEC proposed new rules under the Advisers Act that, if implemented, would be the most significant enhancement of disclosure obligations for private fund managers since the Dodd-Frank Act. Citing investor protection and transparency concerns for limited partners as investors, these proposals signal the Commission’s intent to add additional tools to the fund … Continue Reading
Over the past few years, the SEC has brought fewer insider trading and Material Non-Public Information (MNPI)-related cases compared to historical numbers. We expect to see a reversal of that trend in 2022. The SEC has provided some hints of its renewed focus on insider trading. First, even though the overall number of insider trading … Continue Reading
2021 continued the trend of increased regulatory focus on privacy and cybersecurity for private investment funds in the U.S. and abroad. There are no signs of the trend leveling off any time soon. One of the topics that captured our attention last year was the rise of ransomware. As previously shared, ransomware has evolved from … Continue Reading
Sanctions continue to be a dynamic area of regulation and enforcement. In its first year, the Biden Administration has already undertaken a number of different sanctions initiatives. The three examples below highlight the range of strategies employed and their potential ramifications for private investment funds.… Continue Reading
A threshold question in many cryptocurrency inquiries is whether the digital assets qualify as securities under the federal securities laws. If so, then they are subject to a full suite of federal securities regulations. If not, they still may be subject to AML and other DOJ regulations regarding currencies, as well as the Commodity Futures … Continue Reading
If 2021 was the year in which regulators and investors enthusiastically embraced environmental, social and governance (“ESG”) considerations, by creating new legal and regulatory frameworks, then 2022 will be the year for asset managers to identify and confront the practical challenges of integrating legal requirements and stakeholder expectations into investment policy and performance.… Continue Reading
We reported last year that unprecedented SPAC deal volume signaled an increased risk for disputes given their unique structure, including risks associated with disclosure requirements, material non-public information, valuation, and conflicts of interest. Our assessment proved prescient, as the SEC began to flex its enforcement muscles vis-à-vis SPACs as the year progressed, and took specific … Continue Reading
The SEC’s push to regulate the next generation of blockchain-based applications will likely give rise to disputes and enforcement actions, particularly in the developing decentralized finance (DeFi) space. Although DeFi has the potential to enhance or replace traditional financial products by speeding execution and reducing transaction costs using blockchain technology, the SEC presumes that actors … Continue Reading
Last year, we wrote, “The regulatory and litigation risks for private funds are greater than at any time since the financial crisis in 2008.” That statement is even more true today. The Wall Street Journal recently published separate front-page stories on an SEC initiative to oversee large private companies and the explosive growth of the private … Continue Reading
Complying with the New SEC Marketing Rule: Seven Months in and Still Adapting
By Margaret A. Dale, Michael R. Hackett, William Komaroff, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Robert Pommer, Seetha Ramachandran, Robert Sutton, John Verwey, Jonathan M. Weiss, Julia Alonzo, Julia M. Ansanelli, Charles Bishop, Massimo B. Capizzi, William D. Dalsen, Adam L. Deming, Reut N. Samuels, Michael Singh and Hena M. Vora on Posted in Asset Management, Compliance, Enforcement, Examinations, Regulation, SEC, Securities Law
The Trend Continues: Increased Regulatory Focus on Privacy & Cybersecurity for Private Funds
By Margaret A. Dale, Michael R. Hackett, William Komaroff, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Robert Pommer, Seetha Ramachandran, Robert Sutton, John Verwey, Jonathan M. Weiss, Julia Alonzo, Julia M. Ansanelli, Charles Bishop, Massimo B. Capizzi, William D. Dalsen, Adam L. Deming, Reut N. Samuels, Michael Singh and Hena M. Vora on Posted in Asset Management, Compliance, Cybersecurity, Enforcement, Private Equity, Regulation, SEC
Regulators’ Increased Focus on GP-Led Secondaries and Continuation Funds
By Margaret A. Dale, Michael R. Hackett, William Komaroff, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Robert Pommer, Seetha Ramachandran, Robert Sutton, John Verwey, Jonathan M. Weiss, Julia Alonzo, Julia M. Ansanelli, Charles Bishop, Massimo B. Capizzi, William D. Dalsen, Adam L. Deming, Reut N. Samuels, Michael Singh and Hena M. Vora on Posted in Asset Management, Compliance, Enforcement, Hedge Funds, Private Equity, Regulation, SEC
Energy Transition: A New Risk Climate for Investors
By Margaret A. Dale, Michael R. Hackett, William Komaroff, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Robert Pommer, Seetha Ramachandran, Robert Sutton, John Verwey, Jonathan M. Weiss, Julia Alonzo, Julia M. Ansanelli, Charles Bishop, Massimo B. Capizzi, William D. Dalsen, Adam L. Deming, Reut N. Samuels, Michael Singh and Hena M. Vora on Posted in Asset Management, Compliance, Disputes, Enforcement, Hedge Funds, Private Equity, Regulation, SEC, Securities Law
Ripples Following the SPAC Wave: Litigation and Regulatory Risks
By Margaret A. Dale, Michael R. Hackett, William Komaroff, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Robert Pommer, Seetha Ramachandran, Robert Sutton, John Verwey, Jonathan M. Weiss, Julia Alonzo, Julia M. Ansanelli, Charles Bishop, Massimo B. Capizzi, William D. Dalsen, Adam L. Deming, Reut N. Samuels, Michael Singh and Hena M. Vora on Posted in Asset Management, Compliance, Disputes, Enforcement, Hedge Funds, Private Equity, Private Equity Litigation, Regulation, SEC, Securities Law, SPACs
Messaging Missteps: SEC’s Increasing Focus on Off-Channel Communications
By Margaret A. Dale, Michael R. Hackett, William Komaroff, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Robert Pommer, Seetha Ramachandran, Robert Sutton, John Verwey, Jonathan M. Weiss, Julia Alonzo, Julia M. Ansanelli, Charles Bishop, Massimo B. Capizzi, William D. Dalsen, Adam L. Deming, Reut N. Samuels, Michael Singh and Hena M. Vora on Posted in Asset Management, Compliance, Disputes, Enforcement, Hedge Funds, Private Equity, Private Equity Litigation, Regulation, SEC, Securities Law
SEC Overreach: Insurers Underwrite?
By Margaret A. Dale, Michael R. Hackett, William Komaroff, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Robert Pommer, Seetha Ramachandran, Robert Sutton, John Verwey, Jonathan M. Weiss, Julia Alonzo, Julia M. Ansanelli, Charles Bishop, Massimo B. Capizzi, William D. Dalsen, Adam L. Deming, Reut N. Samuels, Michael Singh and Hena M. Vora on Posted in Asset Management, Compliance, Disputes, Enforcement, Hedge Funds, Private Equity, Regulation, SEC, Securities Law
The New Reality: Valuation in a Volatile Market
By Margaret A. Dale, Michael R. Hackett, William Komaroff, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Robert Pommer, Seetha Ramachandran, Robert Sutton, John Verwey, Jonathan M. Weiss, Julia Alonzo, Julia M. Ansanelli, Charles Bishop, Massimo B. Capizzi, William D. Dalsen, Adam L. Deming, Reut N. Samuels, Michael Singh and Hena M. Vora on Posted in Asset Management, Compliance, Disputes, Enforcement, Hedge Funds, Private Equity, Private Equity Litigation, Regulation, SEC, Securities Law
Crypto Contagion – Managing Risk on Multiple Fronts
By Margaret A. Dale, Michael R. Hackett, William Komaroff, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Robert Pommer, Seetha Ramachandran, Robert Sutton, John Verwey, Jonathan M. Weiss, Julia Alonzo, Julia M. Ansanelli, Charles Bishop, Massimo B. Capizzi, William D. Dalsen, Adam L. Deming, Reut N. Samuels, Michael Singh and Hena M. Vora on Posted in Asset Management, Compliance, Cryptocurrency, Disputes, Enforcement, Hedge Funds, Private Equity, Private Equity Litigation, Regulation, SEC, Securities Law
Portfolio Companies in Distress: Navigating the Risks from SVB and Other Threats to Liquidity and Solvency
By Margaret A. Dale, Michael R. Hackett, William Komaroff, Nathan Lander, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Robert Pommer, Seetha Ramachandran, Robert Sutton, John Verwey, Jonathan M. Weiss, Julia Alonzo, Julia M. Ansanelli, Charles Bishop, Massimo B. Capizzi, William D. Dalsen, Adam L. Deming, Reut N. Samuels, Michael Singh and Hena M. Vora on Posted in Asset Management, Compliance, Disputes, Enforcement, Hedge Funds, News, Private Equity, Private Equity Litigation, Regulation, SEC, Securities Law
Top Ten Regulatory and Litigation Risks for Private Funds in 2023
By Margaret A. Dale, Michael R. Hackett, William Komaroff, Nathan Lander, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Robert Pommer, Seetha Ramachandran, Robert Sutton, John Verwey, Jonathan M. Weiss, Julia Alonzo, Julia M. Ansanelli, Charles Bishop, Massimo B. Capizzi, William D. Dalsen, Adam L. Deming, Reut N. Samuels, Michael Singh and Hena M. Vora on Posted in Asset Management, Compliance, Cryptocurrency, Cybersecurity, Disputes, Enforcement, Hedge Funds, Private Credit, Private Equity, Private Equity Litigation, Regulation, SEC, Securities Law, SPACs, White Collar
Portfolio Company Risk: Plaintiffs Set Sights on Sponsors and Board Directors
By Steven Baker, Margaret A. Dale, Michael R. Hackett, William Komaroff, Kirsten E. Lapham, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Seetha Ramachandran, Jonathan M. Weiss, Robert Sutton, Julia Alonzo, James Anderson, Julia M. Ansanelli, Adam L. Deming, Reut N. Samuels and Hena M. Vora on Posted in Asset Management, Compliance, Disputes, Enforcement, Private Equity, Private Equity Litigation
Conflicts of Interest: How High Will the Bar be Raised?
By Steven Baker, Margaret A. Dale, Michael R. Hackett, William Komaroff, Kirsten E. Lapham, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Seetha Ramachandran, Robert Sutton, Jonathan M. Weiss, Julia Alonzo, James Anderson, Julia M. Ansanelli, William D. Dalsen, Adam L. Deming, Reut N. Samuels and Hena M. Vora on Posted in Asset Management, Compliance, Enforcement, Examinations, Hedge Funds, Private Equity, Regulation, SEC, Securities Law
The Trend of Increasing Disclosure Obligations for Private Funds Continues in 2022
By Steven Baker, Margaret A. Dale, Michael R. Hackett, William Komaroff, Kirsten E. Lapham, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Seetha Ramachandran, Jonathan M. Weiss, Julia Alonzo, James Anderson, Julia M. Ansanelli, William D. Dalsen, Adam L. Deming, Reut N. Samuels and Hena M. Vora on Posted in Asset Management, Compliance, Enforcement, Hedge Funds, Private Equity, Regulation, SEC, Securities Law
Insider Trading, MNPI and Related Internal Controls: A Renewed Focus by SEC
By Steven Baker, Margaret A. Dale, Michael R. Hackett, William Komaroff, Kirsten E. Lapham, Dorothy Murray, Timothy W. Mungovan, Joshua M. Newville, Todd J. Ohlms, Seetha Ramachandran, Jonathan M. Weiss, Julia Alonzo, James Anderson, Julia M. Ansanelli, William D. Dalsen, Adam L. Deming, Reut N. Samuels and Hena M. Vora on Posted in Compliance, Enforcement, Examinations, Private Equity, Regulation, SEC, Securities Law
Increased Regulatory Focus on Privacy and Cybersecurity for Private Funds in 2022
By Steven Baker, Margaret A. Dale, Michael R. Hackett, William Komaroff, Kirsten E. Lapham, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Seetha Ramachandran, Jonathan M. Weiss, Julia Alonzo, James Anderson, Julia M. Ansanelli, William D. Dalsen, Adam L. Deming, Kelly McMullon, Reut N. Samuels and Hena M. Vora on Posted in Asset Management, Compliance, Cybersecurity, Disputes, Enforcement, Private Equity, Regulation
Economic Sanctions and Asset Seizures: An Important Focus for the Biden Administration
By Steven Baker, Margaret A. Dale, Michael R. Hackett, William Komaroff, Kirsten E. Lapham, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Seetha Ramachandran, Jonathan M. Weiss, Julia Alonzo, James Anderson, Julia M. Ansanelli, Adam L. Deming, William D. Dalsen, Amy Gordon, Reut N. Samuels and Hena M. Vora on Posted in Asset Management, Compliance, Enforcement, Private Equity, Regulation, White Collar
Regulatory Shake-Out on Digital Assets: An Industry Waits for Additional Guidance
By Steven Baker, Margaret A. Dale, Michael R. Hackett, William Komaroff, Kirsten E. Lapham, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Seetha Ramachandran, Jonathan M. Weiss, Julia Alonzo, Julia M. Ansanelli, James Anderson, William D. Dalsen, Adam L. Deming, Reut N. Samuels and Hena M. Vora on Posted in Compliance, Cryptocurrency, Disputes, Enforcement, Hedge Funds, Private Equity, Regulation, SEC, White Collar
ESG: Practical Points For Where Market Practice and Legal Trends Collide
By Steven Baker, Margaret A. Dale, Michael R. Hackett, William Komaroff, Kirsten E. Lapham, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Seetha Ramachandran, Jonathan M. Weiss, Julia Alonzo, Julia M. Ansanelli, James Anderson, William D. Dalsen, Adam L. Deming, Reut N. Samuels and Hena M. Vora on Posted in Asset Management, Compliance, Disputes, Enforcement, Hedge Funds, Private Credit, Private Equity, Private Equity Litigation, Regulation, SEC, Securities Law
Treating “Like for Like”: SPAC Disclosure, Marketing and Gatekeeping in 2022
By Steven Baker, Margaret A. Dale, Michael R. Hackett, William Komaroff, Kirsten E. Lapham, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Seetha Ramachandran, Jonathan M. Weiss, Julia Alonzo, James Anderson, Julia M. Ansanelli, William D. Dalsen, Adam L. Deming, Reut N. Samuels and Hena M. Vora on Posted in Asset Management, Compliance, Disputes, Enforcement, Hedge Funds, Private Credit, Private Equity, Private Equity Litigation, Regulation, SEC, Securities Law
Decentralized Finance: The Next Frontier of SEC Enforcement
By Steven Baker, Margaret A. Dale, Michael R. Hackett, William Komaroff, Kirsten E. Lapham, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Seetha Ramachandran, Jonathan M. Weiss, Julia Alonzo, James Anderson, Julia M. Ansanelli, William D. Dalsen, Adam L. Deming, Reut N. Samuels and Hena M. Vora on Posted in Asset Management, Compliance, Cryptocurrency, Disputes, Enforcement, Hedge Funds, Private Credit, Private Equity, Private Equity Litigation, Regulation, SEC, Securities Law
Top Ten Regulatory and Litigation Risks for Private Funds in 2022
By Steven Baker, Margaret A. Dale, Michael R. Hackett, William Komaroff, Kirsten E. Lapham, Timothy W. Mungovan, Dorothy Murray, Joshua M. Newville, Todd J. Ohlms, Seetha Ramachandran, Jonathan M. Weiss, Julia Alonzo, James Anderson, Julia M. Ansanelli, William D. Dalsen, Adam L. Deming, Reut N. Samuels and Hena M. Vora on Posted in Asset Management, Compliance, Cryptocurrency, Cybersecurity, Disputes, Enforcement, Examinations, Hedge Funds, Private Credit, Private Equity, Private Equity Litigation, Regulation, SEC, Securities Law, SPACs, White Collar