The SEC recently settled an enforcement action against an investment adviser and its principal (together, Defendants). The Defendants, who managed three private funds, allegedly failed to monitor or value fund investments, lost access to a digital asset wallet, failed to disclose a potential conflict of interest and improperly allocated expenses to a fund. They also allegedly failed to comply with the custody and compliance requirements of the Investment Advisers Act of 1940. This enforcement action is a good reminder that, among other things, private fund managers must regularly review their documents – including regulatory filings – and update or correct those documents when necessary and must be prepared to produce required records and documents when requested by SEC staff. This article details the SEC’s allegations and the final judgments against the Defendants. See “SEC Sanctions Adviser for Registration, Disclosure and Compliance Violations and Bars Its Inexperienced CCO” (Oct. 28, 2021).