Ares Management Corporation

The SEC instituted a settled enforcement action against Ares Management LLC in May 2020 concerning failures to sufficiently implement and enforce policies designed to prevent misuse of material nonpublic information. The matter arose from Ares having an employee serve on the board of directors of a public company in which an Ares client was invested, creating access to potentially material nonpublic information. The SEC order did not find that Ares or its employees actually misused material nonpublic information. However, it found deficiencies in the implementation and enforcement of Ares' written compliance policies and procedures. Ares consented to a cease-and-desist order, censure, and a $1 million civil penalty. Primary source: Ares Management 2020 Form 10-K describing the SEC order: https://www.sec.gov/Archives/edgar/data/1176948/000162828021003314/ares-20201231.htm