Robert Sutton
St. Petersburg, FL, USA
Former News Producer
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Articles by Robert Sutton
From checkpoints to continuous identity: The biometric future of air travel in APAC
By Robert Sutton, Senior Manager, Strategic Alliances, Biometric Identity Technologies, HID As global air travel surges back to record levels, the aviation industry is undergoing a fundamental shift from recovery to reinvention. Airports and airlines are no longer optimising for throughput alone, they are redesigning the entire passenger journey around one central idea: seamless, trusted identity. Biometrics are now at the heart of this transformation.
Showing Your Work: How SEC Examiners Review the Annual Review
On October 1, 2026, the Securities and Exchange Commission’s Division of Examinations released The SEC Exam Handbook: A Practical Guide on Process and Engagement (the “Handbook”), replacing its examination brochure. On September 14, the Division published a Risk Alert describing recurring deficiencies in the annual compliance reviews required under Rule 206(4)-7 under the Investment Advisers Act (the “Compliance Rule”). Neither document breaks new legal ground.
Showing Your Work: How SEC Examiners Review The Annual Review
On October 1, 2026, the Securities and Exchange Commission’s Division of Examinations released The SEC Exam Handbook: A Practical Guide on Process and Engagement (the “Handbook”), replacing its examination brochure. On September 14, the Division published a Risk Alert describing recurring deficiencies in the annual compliance reviews required under Rule 206(4)-7 under the Investment Advisers Act (the “Compliance Rule”). Neither document breaks new legal ground.
SEC Advances “Responsible Retailization” Through A Potential Accredited Investor Exam And Potential Regulated Fund Reforms
On September 30, 2026, the Securities and Exchange Commission (SEC) issued two rule proposals and five notices aimed at expanding investors’ access to private markets. The package would add ways to qualify as an accredited investor, including passing a new exam administered by the Financial Industry Regulatory Authority (FINRA), broaden performance-based compensation and modernize regulated funds, including interval funds and business development companies (BDCs).
ILPA’s Reporting Templates After PFAR: What Fund Sponsors Should Know
PR Proskauer Rose LLP More The world’s leading organizations and global players choose Proskauer to represent them when they need it the most. Our top tier team of star trial attorneys, acclaimed transactional lawyers and exceptionally talented partners and associates have earned a reputation for the relentless pursuit of perfection and a dauntless pursuit of success.
Beyond the Checkpoint: Rethinking Identity at the Border
Border control has long relied on physical documents and manual inspection to verify identities. But as traveler volumes rise and fraud tactics become more sophisticated, many agencies are questioning whether traditional identity verification methods can keep pace with modern border demands. This challenge is driving a fundamental shift in border management. Identity verification is no longer viewed as a checkpoint process.
SEC 2026 Agenda: Key Takeaways For Investment Advisers And Investment Companies
PR Proskauer Rose LLP More The world’s leading organizations and global players choose Proskauer to represent them when they need it the most. Our top tier team of star trial attorneys, acclaimed transactional lawyers and exceptionally talented partners and associates have earned a reputation for the relentless pursuit of perfection and a dauntless pursuit of success.
SEC Division Of Examinations Highlights Deficiencies In Advisers’ Management And Disclosure Of Economic Conflicts Of Interest
Proskauer Rose LLP are most popular: within Insurance topic(s) On June 9, 2026, the Securities and Exchange Commission’s (“SEC”) Division of Examinations (“Division”) issued a risk alert (“Risk Alert”) summarizing examination findings concerning SEC-registered investment advisers’ duty to address economic conflicts of interest.
Identity Systems in Action: What Defines Biometric Performance Success in Air Travel
5:21 AM A family of four arrives at an airport security checkpoint already running behind schedule. The line moves — reluctantly. One biometric kiosk is rebooting. Another asks travelers to try again. A staff member steps in to assist, but tension is building. Fast forward to the boarding area. A traveler steps up to the biometric boarding gate. The system scans his face. Pauses. Scans again. A red light flashes. He tries once more. Same result. The queue behind him groans. Phones come out.
SEC And CFTC Propose Rollback Of Form PF Requirements
Proskauer Rose LLP are most popular: within Insurance topic(s) On April 20, 2026, the Securities and Exchange Commission and the Commodity Futures Trading Commission (the “Agencies”) jointly proposed amendments to Form PF (the “Proposal”) that would materially reduce reporting burdens for private fund advisers.
SEC’s Division Of Investment Management Clarifies Certain Questions On Fund Of Funds Rule
Proskauer Rose LLP are most popular: within Insurance topic(s) with readers working within the Banking & Credit industries On March 5, 2026, the staff of the SEC's Division of Investment Management (the "Staff") published four new frequently asked questions (the "FAQs") addressing Rule 12d1-4 under the Investment Company Act of 1940 (the "1940 Act"), the comprehensive rule governing fund of funds arrangements adopted by the SEC in October 2020.
SEC Permits Confidential Treatment Requests For Form ADV Information
Nathan Schuur’s articles from Proskauer Rose LLP are most popular: with Senior Company Executives, HR and Inhouse Counsel in United States with readers working within the Media & Information and Law Firm industries On December 29, 2025, the Securities and Exchange Commission (the "SEC") issued a final rule delegating authority to the Director (the "IM Director") of the Division of Investment Management ("IM") to grant, deny, and revoke requests for confidential treatment under Section 210(a)...
SEC Issues Risk Alert To Remind Advisers Of Core Compliance Expectations
PR Proskauer Rose LLP More The world’s leading organizations and global players choose Proskauer to represent them when they need it the most. Our top tier team of star trial attorneys, acclaimed transactional lawyers and exceptionally talented partners and associates have earned a reputation for the relentless pursuit of perfection and a dauntless pursuit of success.
SEC Issues Risk Alert to Remind Advisers of Core Compliance Expectations
On December 16, 2025, the Securities and Exchange Commission’s ("SEC") Division of Examinations issued a Risk Alert highlighting several recurring deficiencies in investment advisers’ compliance with the provisions of Advisers Act Rule 206(4)-1 (the “Marketing Rule”) governing use of testimonials and endorsements as well as third-party ratings. These observations serve as useful reminders of the basic compliance expectations that advisers must continue to uphold.
SEC Again Extends Short Sale And Securities Lending Rules' Compliance Deadlines To 2028 While It Considers Response To Court Ruling
Robert H. Sutton’s articles from Proskauer Rose LLP are most popular: within Corporate/Commercial Law topic(s) in United States Proskauer Rose LLP are most popular: within Environment and Energy and Natural Resources topic(s) with readers working within the Banking & Credit industries On December 3, 2025, the Securities and Exchange Commission (the "SEC") issued an exemptive order to postpone the compliance deadline for Rule 13f-2 under the Securities Exchange Act of 1934 by two years.
Supreme Court To Decide Whether Section 47(b) Creates A Private Right Of Action Under The Investment Company Act Of 1940
Nathan Schuur’s articles from Proskauer Rose LLP are most popular: with Senior Company Executives, HR and Inhouse Counsel with readers working within the Media & Information industries Overview On December 10, 2025, the United States Supreme Court will hear arguments in FS Credit Opportunities Corp. v. Saba Capital Master Fund, Ltd. to resolve a circuit split and determine whether there is a private right of action for violations of the Investment Company Act of 1940, as amended (the "1940 Act").
The 5 AI Tensions Leaders Need to Navigate
The 5 AI Tensions Leaders Need to Navigate Based on insights from more than 100 builders, executives, investors, advisors, and researchers from across the globe. by Rebecca Hinds and Robert I. Sutton December 10, 2025 When Polish endoscopists began using AI to detect cancer, their accuracy improved. But their performance on non-AI procedures got worse. When students used AI to draft SAT-style essays, their creativity initially spiked.
FinReg Monthly Update
Welcome to Proskauer’s FinReg Monthly Update, a regular bulletin highlighting the latest developments in UK and EU financial services regulation. 17 November – Liquidity Management RTS: The European Commission has adopted Delegated Regulations containing regulatory technical standards (RTS) on liquidity management tools under the Alternative Investment Fund Managers Directive (2011/61/EU) (AIFMD) and the UCITS Directive (2009/65/EC).
Your Face, Your Journey: How Smart Airports Use Facial Recognition To Put Passengers First
Airports today are no longer just places travelers pass through — slowly and frustratingly. They are evolving into intelligent, adaptive ecosystems. The goal? To make every step of the journey faster, safer and more seamless. With rising passenger volumes and mounting cost pressures, airport leaders face a tough mandate: deliver secure, seamless and sustainable experiences while improving efficiency. The solution? Strategic digital modernization — and at the core of it is facial recognition.
Balancing seamless travel with security and ethics in 2025
Facial recognition is promising faster travel and stronger security, but only if governments deploy it ethically, transparently and with safeguards that earn public trust. As global travel rebounds and international mobility gains momentum, border control authorities are increasingly turning to biometric technologies to modernise how people cross borders.
The Rise Of The Zombie Fund: Managing Regulatory Risk Associated With Long-Lived Fund Vehicles
Robert H. Sutton’s articles from Proskauer Rose LLP are most popular: within Finance and Banking topic(s) in United States with readers working within the Banking & Credit industries Private fund managers and investors have long been haunted by the risk of a "zombie" fund: an investment vehicle that lasts well past its initial term, potentially creating regulatory risk.1 While every situation will present different challenges, certain issues arise time and again.
The Countdown to EES: What Airports Need to Know About Europe’s Biometric Border Control Shift
The clock is ticking. Starting October 12, 2025, the European Union will begin rolling out its long-anticipated Entry/Exit System (EES) — a sweeping upgrade to how borders are managed across the 29 Schengen countries. If you’re a non-EU traveler, say goodbye to passport stamps and hello to biometric registration. By April 10, 2026, this system will be fully operational, transforming the way millions move through Europe’s airports. As for airports? It’s go-time.
FTC Releases Shutdown Plan, Will Continue To Accept HSR Filings
The Federal Trade Commission ("FTC") released a shutdown plan dated September 29, 2025, outlining how it will operate during this lapse in appropriations. FTC Commissioners are presidential appointees and are excepted from furlough during the shutdown. According to the shutdown plan, furloughs will be issued on a rolling basis for the staff to properly address the agency's docket for competition, consumer protection, and other matters pending in litigation.
SEC Guidance On The Government Shutdown
PR Proskauer Rose LLP More The world’s leading organizations and global players choose Proskauer to represent them when they need it the most. Our top tier team of star trial attorneys, acclaimed transactional lawyers and exceptionally talented partners and associates have earned a reputation for the relentless pursuit of perfection and a dauntless pursuit of success. As of 12:01 am on October 1, 2025, congressionally appropriated funding lapsed for most operations of the United States government.
FinCEN Formally Proposes Two-Year Delay Of Investment Adviser AML Rule
FinCEN has formally proposed to delay the effective date of the investment adviser AML rule from January 1, 2026, to January 1, 2028. The amendment itself is narrowly tailored to delaying the effective date, leaving the substance of the rule intact. However, FinCEN has made clear that it may propose further substantive changes before the rule takes effect. Advisers should treat this as both regulatory relief and a signal that the contours of their future AML obligations remain unsettled.
SEC Again Extends Form PF Compliance Deadline To October 1, 2026
On September 17, 2025, the Securities and Exchange Commission (the "SEC") voted to postpone once more the compliance deadline for the Form PF amendments adopted in February 2024. The deadline, previously set for October 1, 2025, has now been extended by one year to October 1, 2026. This is the SEC's third such extension in 2025, having previously approved extensions in January and June.
Your Face Is Your Boarding Pass: How Facial Recognition Is Reshaping Air Travel
Long lines. Repetitive ID checks. Missed connections. Millions of travelers face these frustrations every year. But what if that experience could be transformed — not just improved, but reimagined? That’s exactly what facial recognition is doing. From check-in to boarding, your face is becoming your boarding pass to a smoother journey. Why Now? The shift didn’t happen overnight. The pandemic accelerated the demand for touchless, self-service experiences.
What To Expect When You're Expecting New Investors - Practical Steps Fund Managers Can Take To Prepare For Investments From Registered Funds And Defined Contribution Retirement Plans - Fund Management/ REITs - United States
Historically, investments in private funds have been reserved for large institutions, defined benefit pension plans, sovereign wealth funds and very wealthy individuals. In recent years, though, the notable difference in returns between private investments and those available in the public markets has increased pressure to expand access to private-market investments for "Main Street" investors.
SEC Cites Falsified Compliance Records In Two Recent SEC Settlements With CCOs
Two SEC enforcement actions from earlier this month, each including charges against a firm's Chief Compliance Officer in their personal capacity, underscore the importance of maintaining accurate records and upholding transparency during regulatory examinations. While the cases differ in detail, both focus on allegations that the CCO provided misleading information to regulators during an exam—highlighting one of the principal ways that individual liability can arise.
SEC Cites Falsified Compliance Records in Two Recent SEC Settlements with CCOs
Two SEC enforcement actions from earlier this month, each including charges against a firm’s Chief Compliance Officer in their personal capacity, underscore the importance of maintaining accurate records and upholding transparency during regulatory examinations. While the cases differ in detail, both focus on allegations that the CCO provided misleading information to regulators during an exam—highlighting one of the principal ways that individual liability can arise.
Treasury To Delay Investment Adviser AML Rule To 2028, Announces Intent To Reconsider AML And CIP Rules
On July 21, 2025, the Department of the Treasury announced a two-year postponement of the much-anticipated anti-money laundering (AML) rule, adopted by Treasury's Financial Crimes Enforcement Network (FinCEN) in 2024, requiring investment advisers to implement AML programs that comply with the Bank Secrecy Act (BSA) and file suspicious activity reports (SARs). The implementation date, previously set for January 1, 2026, will be delayed until at least January 1, 2028.
From Wall Street To Main Street: Investor Advocate Puts Private Funds On The 401(k) Horizon
On June 25, 2025, the SEC's Office of the Investor Advocate (OIAD) released its annual report to Congress on its policy priorities for fiscal year 2026. The office was established by Congress to focus on retail investor issues and, in many years, its annual report draws limited attention.
SEC Formally Withdraws Fourteen Rule Proposals
PR Proskauer Rose LLP More The world’s leading organizations and global players choose Proskauer to represent them when they need it the most. Our top tier team of star trial attorneys, acclaimed transactional lawyers and exceptionally talented partners and associates have earned a reputation for the relentless pursuit of perfection and a dauntless pursuit of success. On June 12, 2025 the Securities and Exchange Commission ("SEC") formally withdrew fourteen outstanding...
SEC Formally Withdraws Fourteen Rule Proposals
On June 12, 2025 the Securities and Exchange Commission (“SEC”) formally withdrew fourteen outstanding rule proposals issued by the prior administration.
SEC Further Extends Form PF Compliance Date And Signals Broader Reconsideration
On June 11, 2025, the Securities and Exchange Commission ("SEC") voted to extend the compliance date for the most recently adopted amendments to Form PF by approximately four months, to October 1, 2025. The amendments were adopted jointly by the SEC and the Commodity Futures Trading Commission ("CFTC") on February 8, 2024, with an initial compliance date of March 12, 2025.
On June 11, 2025, the Securities and Exchange Commission (“SEC”) voted to extend the compliance date for the most recently adopted amendments to Form PF by approximately four months, to October 1, 2025. The amendments were adopted jointly by the SEC and the Commodity Futures Trading Commission (“CFTC”) on February 8, 2024, with an initial compliance date of March 12, 2025.
Raising The Bar: SEC Evaluating An Increase In Minimum AUM Threshold For Investment Adviser Registration
On April 8, 2025, Acting SEC Chairman Mark T. Uyeda gave a speech signaling that the SEC may revisit the current minimum assets under management ("AUM") threshold for federal registration, potentially reducing the number of investment advisers required to register with the SEC. Though Uyeda's time as Acting Chair has now ended due to the confirmation of Paul Atkins as SEC Chair, Uyeda's willingness to raise the issue publicly suggests he expects Atkins will carry the initiative forward.
Raising the Bar: SEC Evaluating an Increase in Minimum AUM Threshold for Investment Adviser Registration
On April 8, 2025, Acting SEC Chairman Mark T. Uyeda gave a speech signaling that the SEC may revisit the current minimum assets under management (“AUM”) threshold for federal registration, potentially reducing the number of investment advisers required to register with the SEC. Though Uyeda’s time as Acting Chair has now ended due to the confirmation of Paul Atkins as SEC Chair, Uyeda’s willingness to raise the issue publicly suggests he expects Atkins will carry the initiative forward.
New Tariffs, Old Issues: Post-Liberation Day Advisers Act Considerations For Private Fund Managers
Markets remain exceptionally volatile following the announcement of the U.S. "Liberation Day" tariffs and retaliatory measures from other countries. While the ultimate path of policy remains uncertain, recent developments are likely to exert continued pressure on valuations and liquidity across private fund portfolios (even if certain policies are paused or rolled back).
The SEC Under Paul Atkins - What To Expect For Registered And Private Offerings, Climate-Related Disclosure, Consolidated Audit Trail, Digital Assets, And Agency Re-Organization - Securities - United States
Paul Atkins, who has been nominated by President Trump to serve as Chairperson of the Securities & Exchange Commission, last week completed a short confirmation hearing before the U.S. Senate Banking Committee. Despite its brevity, the hearing provided meaningful clues to Mr. Atkin's plans if he is confirmed by the Senate to lead the SEC, which appears reasonably assured to occur. On April 3, 2025, the Senate Banking Committee approved his nomination with a vote 13 to 11.
New Interim Rule Removes CTA Reporting Requirements For U.S. Companies And U.S. Persons
On March 21, 2025, the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN") issued an interim final rule to the U.S. Corporate Transparency Act ("CTA") that eliminates beneficial ownership information ("BOI") reporting requirements for domestic entities and U.S. persons. The immediate result of the interim final rule is that no U.S. entities are required to register or update any BOI reports, and no beneficial owners who are U.S. persons are required to provide BOI.
Facial Recognition Is Transforming Air Travel Passenger Processing Recognition Is Transforming Air Travel Passenger Processing
The skies are set to get a whole lot busier. By 2040, air travel is projected to reach a staggering 8 billion passengers annually. To manage this influx efficiently, airports, airlines and government authorities are turning to cutting-edge biometric technologies to better navigate congested terminals. Since airports run on identity verification, implementing accurate, high-throughput authentication solutions is critical to delivering an exceptional traveler experience today and tomorrow.
Treasury Announces Non-Enforcement Of The Corporate Transparency Act For Domestic Entities
On March 2, 2025, the U.S. Department of the Treasury issued a press release announcing that it would not enforce any penalties or fines or take other enforcement actions against U.S. citizens or domestic reporting companies or their beneficial owners regarding compliance with the Corporate Transparency Act (the "CTA"), even after forthcoming rule changes take effect.
Corporate Transparency Act Deadlines On Hold
On February 27, 2025, the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN") announced that it would not issue any fines or penalties or take other enforcement actions for a failure to comply with the current deadlines under the Corporate Transparency Act (the "CTA"). The CTA had been subject to a number of injunctions against enforcement over the past several months, the last of which was lifted on February 18, 2025.
Treasury Announces Non-Enforcement of the Corporate Transparency Act for Domestic Entities
On March 2, 2025, the U.S. Department of the Treasury issued a press release announcing that it would not enforce any penalties or fines or take other enforcement actions against U.S. citizens or domestic reporting companies or their beneficial owners regarding compliance with the Corporate Transparency Act (the “CTA”), even after forthcoming rule changes take effect.
Corporate Transparency Act Deadlines on Hold
On February 27, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced that it would not issue any fines or penalties or take other enforcement actions for a failure to comply with the current deadlines under the Corporate Transparency Act (the “CTA”). The CTA had been subject to a number of injunctions against enforcement over the past several months, the last of which was lifted on February 18, 2025.
Tailoring MFA Solutions to Your Business Needs
Realizing the Promise of Secure, Flexible Workforce Authentication Stop us if you’ve heard this one: MFA is a must-have in enterprise security. The logic is straightforward. At a time when the cost of a single breach averages in millions of dollars — and the number of exposed records is often counted in billions — MFA is a critical way to protect data and guard against stolen credentials, which is still the most common vector for attacks.
How Biometrics Are Transforming Air Travel: Insight From HID’s Aviation Industry Expert
Is your terminal prepared to handle the imminent global travel surge? With passenger numbers projected to reach 8 billion annually by 2040, airports, airlines and border control face significant scaling challenges — ranging from staffing shortages, space constraints and a reliance on existing technologies that simply cannot facilitate the burgeoning demand.
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