Action against Respondent, the founder, CEO, and CIO of an investment advisory company, for alleged failure to maintain adequate controls. According to the SEC, Respondent knew that his company’s compliance program was underfunded but failed to address the deficiency, which resulted in compliance failures. The SEC further alleges that Respondent failed to put in place adequate due diligence and monitoring policies. Respondent has agreed to pay a civil penalty of $45,000. In a related proceeding, Respondent’s company has agreed to pay a civil penalty of $400,000.