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The U.S. Securities and Exchange Commission ("SEC") has, to our understanding, delivered letters of inquiry to at least 10 hedge funds, banks, and private equity firms requesting information about the firms' interactions with sovereign wealth funds ("SWF"). That list may expand to include other financial institutions. The investigation appears to be driven by: (i) the SEC's opinion that SWF employees are foreign government officials for purposes of the Foreign Corrupt Practices Act ("FCPA"); and (ii) reports that certain hedge funds, banks, and private equity firms may have paid bribes to those government officials to attract or retain business.