The allocation of profitable trades to favored accounts at the expense of others is a perennial subject of SEC enforcement activity. In its latest action on the issue, the SEC announced settled charges against a registered investment adviser for failing to detect and prevent an alleged cherry picking scheme by its former co‑chief investment officer. The adviser agreed to pay a $100‑million civil penalty, according to the order (Order) issued on June 5, 2026. The SEC faulted the firm less for the trading itself – which remains the subject of separate, contested proceedings against the former executive – than for its failure to police such trading and enforce its own written policies. This article analyzes the conduct at issue; the alleged compliance and supervisory failures; and the terms of the Order. See “CFTC Goes After CPO/CTA and Principal in Alleged Cherry Picking Scheme” (Mar. 28, 2024); “Adviser and Principal Sanctioned for Violations Associated With Representative’s Cherry Picking Scheme” (Oct. 27, 2022); and “SEC Charges Private Fund CCO in Cherry Picking Scheme” (Jul. 29, 2021).