Regulatory action by US Securities and Exchange Commission: cease and desist
Fund concerned: none named in the filing. The matter concerns the adviser itself, not a specific fund, and none of the insurance-dedicated funds in this file is named.
On January 13, 2025, the U.S. Securities and Exchange Commission ("SEC") issued a settled administrative order finding that Apollo Capital Management, LP ("Apollo") willfully violated Section 204 of the Investment Advisors Act of 1940 (the "Advisers Act") and Rule 204-2(a)(7) thereunder. The order also found that Apollo failed to reasonably supervise its employees within the meaning of Advisers Act Section 203(e)(6). Specifically, the order found that from at least December 2019 to January 13, 2025, Apollo personnel sent and received communications on platforms that were not approved for business purposes, many of which were not preserved by Apollo on firm systems. In numerous instances, ...