Notwithstanding expectations of a lighter enforcement touch under SEC Chair Paul Atkins, the SEC enforcement proceeding against a registered investment adviser suggests the agency will continue to hold advisers accountable for strict compliance with its rules. The adviser allegedly made unsubstantiated claims on its website to the effect that it “refused all conflicts of interest,” even though it acknowledged having conflicts in other documents. The SEC claimed the adviser violated the Marketing Rule; failed to maintain required books and records; conducted inadequate annual compliance reviews; and failed to follow its policies and procedures. This article discusses the resolution, which is also an important reminder that substantive violations often lead to associated compliance-related charges. See “Acting SEC and CFTC Chairs Emphasize Getting ‘Back to the Basics’” (May 8, 2025).