VICTORY CAPITAL HOLDINGS INC
VCTR
Financials
1
exclusion reason
1 theme
This page is part of our public exclusion list — a transparency tool that shows which companies we screen out and why. It is not investment advice, and it is not an accusation. But it is subject to change as our understanding of the facts evolves.
Victory Capital Holdings was identified in the SEC's and FINRA's industry-wide enforcement sweep targeting off-channel communications recordkeeping violations. The SEC's 2024 enforcement action (Press Release 2024-114) charged multiple investment advisers for widespread, systemic failure to preserve electronic communications required under the Investment Advisers Act. Personnel at these firms routinely used unapproved platforms such as WhatsApp and personal text messages for business communications that are legally required to be preserved for insider trading and market manipulation surveillance. FINRA's targeted examination letters on off-channel communications further highlighted the scope of non-compliance among asset management firms. The SEC's off-channel enforcement initiative, spanning 2021-2025, has resulted in over $2 billion in combined penalties across approximately 70 firms, representing the most significant recordkeeping enforcement campaign in SEC history.
Research Sources
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A digest of changes to our exclusion list — new additions, removals, and the evidence behind them. We review the list continuously as new evidence surfaces.
Companies appear on our exclusion list based on our investment judgment — not because they've done anything illegal. This is a difference of values and opinion, not an accusation of wrongdoing. Exclusion does not constitute a recommendation against investing in any company, and absence from the list does not constitute a recommendation to invest.
This information is provided for educational and transparency purposes only and should not be relied upon as investment advice. Data is drawn from independent watchdogs, NGOs, government registries, and Ethical Capital's ongoing research — see Research Sources for the full list.
Ethical Capital LLC is a state-registered investment adviser in Utah (CRD #316032). Registration does not imply a certain level of skill or training.