SEC and state regulatory compliance
review, compliance program assessments, surveillance, conflicts of interest management, and regulatory filing support for registered advisers.
Compliance programs built to withstand examination.
Institutional-grade compliance leadership, without the institutional overhead. ComplyOn LLC provides senior compliance and risk advisory to institutional asset managers, investment advisers, , and firms — built on more than sixteen years at the intersection of regulation, governance, and operations.
16+
Years leading regulatory compliance programs
$53B+
Institutional assets under compliance oversight
Zero
Findings across eight internal and three external audits
Figures reflect cumulative professional experience of the founder.
Reema Keen
Founder & Principal, ComplyOn LLC
About the firm
Senior compliance expertise, delivered with precision.
ComplyOn LLC is an Atlanta-based independent compliance and risk advisory practice founded by Reema Keen, a compliance leader with more than sixteen years of experience building and overseeing regulatory compliance programs across -registered investment advisers, , , and .
Most recently, Reema served as Managing Director and Chief Compliance Officer at a $3 billion SEC-registered Outsourced Chief Investment Officer firm, where she institutionalized and enhanced the compliance program and brought the firm to full SEC examination readiness. Before that, she held senior compliance and operations leadership roles at UPS Investments Group, a $50B+ institutional pension fund, overseeing governance and due diligence across more than 200 investment managers. Earlier in her career, she supported enterprise-wide / remediation following a .
ComplyOn pairs senior-level judgment with a collaborative, scalable delivery model. Reema leads each engagement personally and works alongside clients' legal counsel, auditors, and administrators, drawing on trusted specialist partners and technology where a mandate calls for additional expertise or capacity. The aim is a long-term partnership: the right expertise, applied at the right scale, as each firm grows.
Areas of expertise
SEC regulatory complianceAML, OFAC & financial crimeERISA & DOL advisoryGovernance, risk & controls
Compliance is not a constraint on business. It is the foundation on which lasting institutions are built.
Reema KeenFounder & Principal, ComplyOn LLC
What we do
Compliance services for institutional complexity.
ComplyOn delivers senior advisory across the full compliance lifecycle — with the depth of an in-house and the flexibility of an independent consultant.
& financial crime
Program design, gap assessments, screening frameworks, and enforcement action remediation support.
Operational Due Diligence
frameworks for platforms and institutional allocators overseeing external managers, covering custody, , , and across investment managers spanning public, private, illiquid, and offshore fund structures.
Contract review & advisory
Compliance-focused review of investment management and sub-advisory agreements, custodian agreements, and — identifying regulatory risk and governance gaps before execution.
Governance, risk & controls
Enterprise framework design, board and committee governance review, cybersecurity policy development, control testing, and board-level reporting — including AI governance: use inventories, acceptable use policies, AI vendor due diligence, and review of AI-related disclosures.
ERISA & DOL advisory
Governance and fiduciary compliance, prohibited transaction analysis, and operational due diligence frameworks for pension and institutional investment environments.
Fractional CCO services
Dedicated compliance leadership on a part-time basis — program ownership, compliance training, and regulatory interface, scaled to the size and stage of your organization.
Ongoing compliance support
Recurring support alongside your existing team — compliance calendar management, annual review and risk assessment, and advice on new or amended regulations, at whatever cadence your firm needs.
Digital asset frameworks
, custody, and safeguarding frameworks for investment advisers and funds with digital asset exposure, applying institutional compliance standards to requirements emerging under and rules and regulations.
Who we serve
Firms where the regulatory stakes are highest.
Engagements span and the managers who serve them.
Investment advisers
-registered , and managers.
OCIO firms
Outsourced Chief Investment Officer platforms managing , institutional-scale portfolios, where oversight and manager carry their own compliance demands.
Pension funds
Corporate and public navigating and requirements.
Endowments & foundations
Nonprofit and foundations navigating and governance standards.
Digital asset managers & funds
Investment advisers and funds with digital asset exposure building , and safeguarding frameworks aligned with and requirements.
Venture & emerging managers
Emerging and established venture capital fund managers, including those backing digital asset and blockchain companies, building institutional-grade compliance programs and navigating regulatory change as they raise capital and grow.
Track record
Programs built, examinations passed, findings avoided.
Selected outcomes from sixteen years inside institutional compliance programs — the problems ComplyOn was built to solve for other firms.
Disciplina Capital Management
-registered $3B
Institutionalized a and brought the firm to full SEC examination readiness.
Institutionalized and significantly enhanced the firm’s compliance infrastructure, establishing the policies, controls, monitoring, and governance expected of a mature institutional adviser. Led the review process and the annual review audit, coordinated audits, and set the documentation standards that brought the firm to full examination readiness.
UPS Investments Group
$50B+ institutional pension fund
Eleven audits. Zero findings.
Supported eight internal and three external audits without a single finding, across governance, operational due diligence, cybersecurity, and — the result of controls designed to be tested rather than defended after the fact.
Multi-manager oversight at scale
Held 200+ external managers to one oversight standard.
Built and ran the due diligence, monitoring, and conflict-of-interest framework covering more than 200 investment managers across single-manager and multi-manager platforms, spanning public, private, illiquid, and — the same problem platforms and face today.
New regulation implementation
Brought a corporate pension into compliance with the .
Implemented the collateral program end to end — a worked example of translating a new rule into operational reality across custodians, counterparties, and internal teams.
HSBC Securities Inc.
Global broker-dealer under enforcement
Remediated an / program under a consent order.
Supported enterprise-wide remediation following a Department of Justice enforcement action, managing screening and risk escalation across customer and counterparty relationships and delivering executive-level reporting on sanctions, anti-bribery, and staff dealing risk.
Elara Securities Inc.
Boutique investment bank, first-time
Registered a firm with and cleared it to transact with U.S. institutions.
Played a central role in the firm's registration, prepared and filings across eight transactions, advised on marketing offshore fund structures under and , and helped secure the license to offer secondary debt and equity securities to U.S. institutional investors.
How we work together
Engagement models built around your stage.
Every service area above can be delivered under any of these three models. Each engagement starts with a conversation about your firm, your regulators, and where the gaps actually sit; a proposal follows.
Outsourced
Fractional CCO
Hand off day-to-day compliance ownership to a senior advisor, without adding headcount (for selective engagements).
- Program ownership and
- Testing, remediation, and documentation
- Employee reporting and training
- , filings, and exam coordination
Monthly retainer
Ongoing
Compliance support
Recurring support alongside your existing team, as much or as little as you need.
- management
- and
- Advice on new or amended regulations
Monthly retainer or hourly
Project
Defined engagements
A specific compliance problem scoped and solved, with documentation your team can run with.
- Program builds and registration support
- reviews
- New regulation implementation
- Contract review and framework design
- and exam prep
Hourly or flat fee
Common questions
Answers before we connect.
Do you provide compliance services for broker-dealers?
No. ComplyOn focuses exclusively on investment advisers, OCIOs, pension funds, endowments and foundations, venture and emerging managers, and digital asset managers and funds. Reema's background includes broker-dealer compliance experience, but the firm does not currently offer broker-dealer compliance services.
What is a fractional Chief Compliance Officer?
A fractional CCO is a senior compliance professional who serves as a firm's Chief Compliance Officer on a part-time basis, giving the firm dedicated compliance leadership without adding headcount. At ComplyOn, a fractional CCO engagement covers program ownership and the regulatory interface; testing, remediation, and documentation; employee reporting and training; and Form ADV, filings, and exam coordination. It is billed as a monthly retainer, and ComplyOn takes on these roles selectively.
Do regulators allow an outsourced or fractional Chief Compliance Officer?
Yes. The CCO may be in-house or outsourced, provided the individual is knowledgeable about applicable regulations and has sufficient authority and access to senior management to implement and enforce the compliance program.
What does an engagement cost?
It depends on scope. Fractional CCO engagements are billed as a monthly retainer, ongoing support as a retainer or hourly rate, and project-based work as an hourly or flat fee. A proposal follows an initial conversation about your firm and needs.
How do you help firms prepare for an SEC examination?
ComplyOn's examination readiness work includes compliance program assessments, Form ADV review, mock exams, and SEC exam preparation, delivered as a defined project or as part of a fractional CCO or ongoing support engagement. Most recently, Reema Keen served as Managing Director and Chief Compliance Officer at a $3 billion SEC-registered OCIO, where she brought the firm to full SEC examination readiness.
Do you work with firms that don't yet have a registered adviser or a formal compliance program?
Yes. ComplyOn supports firms building a compliance program from the ground up, including registration support, initial policy drafting, and governance infrastructure — as well as firms with mature programs seeking an experienced second set of eyes.
Can you support a firm with digital asset exposure?
Yes. ComplyOn works with investment advisers and funds with digital asset exposure, building AML, custody, and safeguarding frameworks that apply institutional compliance standards to requirements emerging under SEC, CFTC, and FinCEN rules and regulations.
How do you help firms keep pace with regulatory change?
Through ongoing compliance support or a defined project, ComplyOn tracks new and amended rules relevant to your firm, assesses their impact on your program, and helps implement the policy, procedural, and operational changes they require — before an examination tests them.
Do you help firms govern their use of AI?
Yes, as part of ComplyOn's governance, risk and controls work. That includes inventorying how AI tools are used across the firm, drafting acceptable use policies, conducting due diligence on AI vendors, reviewing Form ADV and marketing materials so AI-related claims match actual practice, addressing supervision and recordkeeping for AI-generated communications and meeting note-takers, and training staff. How advisers supervise their use of AI, and whether their representations about it are accurate, is a current focus of SEC examinations.
Do you use AI tools in your own work?
Yes, selectively and with safeguards. ComplyOn uses enterprise-grade AI tools to work more efficiently, does not enter client confidential information into consumer or public AI tools without the client's consent, and reviews all work product personally. Responsibility for every deliverable rests with Reema, not with a tool.
Who leads ComplyOn?
ComplyOn was founded by Reema Keen, who leads every engagement personally. Reema has more than sixteen years of experience building and overseeing regulatory compliance programs across SEC-registered investment advisers, institutional pension funds, broker-dealers, and global financial institutions. Most recently she was Managing Director and Chief Compliance Officer at a $3 billion SEC-registered OCIO; before that she held senior compliance and operations leadership roles at UPS Investments Group, a $50B+ institutional pension fund, overseeing governance and due diligence across more than 200 investment managers.
Do you work alongside other professionals?
Yes. Reema leads each engagement personally and works alongside a client's legal counsel, auditors, fund administrators, and technology providers, bringing in trusted specialist partners where an engagement calls for additional expertise or capacity. ComplyOn provides compliance consulting and does not provide legal, tax, or investment advice.
Get in touch
Let's discuss your compliance needs.
Whether you need fractional support, a program assessment, or ongoing advisory, ComplyOn is ready to engage. All inquiries are handled with strict confidentiality.
Phone
Location
LinkedIn