In a recent speech, the SEC’s Director of Enforcement, Robert Khuzami, said that the SEC is “utilizing data and risk-based analytics to identify the early-warning signs of fraud.”  For example, the Enforcement Division is reviewing ADVs for “high-risk investment advisers” to determine “who is lying about their educational achievements, their business affiliations, and their assets under management.”  He said that the Enforcement Division is also analyzing databases to “identify mutual funds that exhibit poor performance, have relatively high fee arrangements, and sub-advisers.”  Mr. Khuzami compared his approach to that of Rudy Giuliani in New York:  â€œFor Rudy, it was a focus on subway turnstile-jumpers and squeegee-men.  For us, it’s advisers who lie about graduating Phi Beta Kappa, conceal their association in a past failed business venture, or inflate their assets under management who might well be the same persons who outright steal your money when the markets turn against them.”  Separately, the Enforcement Division has indicated that lax compliance programs could also lead to more serious violations.