The firms admitted the facts set forth in their respective SEC orders, acknowledged that their conduct violated recordkeeping provisions of the federal securities laws, agreed to pay combined civil penalties of $63.1 million, as outlined below, and have begun implementing improvements to their compliance policies and procedures to address these violations. One of the firms, as noted below, self-reported its violations and, as a result, will pay significantly lower civil penalties than it would have otherwise.

• Blackstone Alternative Credit Advisors LP, together with Blackstone Management Partners L.L.C. and Blackstone Real Estate Advisors L.P., agreed to pay a combined $12 million penalty;
• Kohlberg Kravis Roberts & Co. L.P. agreed to pay a $11 million penalty;
• Charles Schwab & Co., Inc. agreed to pay a $10 million penalty;
• Apollo Capital Management L.P. agreed to pay a $8.5 million penalty;
• Carlyle Investment Management L.L.C., together with Carlyle Global Credit Investment Management L.L.C., and AlpInvest Partners B.V., agreed to pay a combined $8.5 million penalty;
• TPG Capital Advisors LLC agreed to pay an $8.5 million penalty;
• Santander US Capital Markets LLC agreed to pay a $4 million penalty;
• PJT Partners LP, which self-reported, agreed to pay a $600,000 penalty.

“In order to effectively carry out their oversight responsibilities, the Commission’s Examinations and Enforcement Divisions must, and indeed do, rely heavily on registrants complying with the books and records requirements of the federal securities laws. When firms fall short of those obligations, the consequences go far beyond deficient document productions; such failures implicate the transparency and the integrity of the markets and their participants, like the firms at issue here,” said Sanjay Wadhwa, Acting Director of the SEC’s Division of Enforcement. “In today’s actions, while holding firms responsible for their recordkeeping failures, the Commission once more recognized and credited a registrant’s self-report, demonstrating yet again that there are tangible benefits to be gained from proactive cooperation.”