Firm profile

Sculptor Advisors LLC

NEW YORK, NYCRD 319598Registration Status: ApprovedEffective since July 7, 2022SEC # 801-125965Latest ADV October 9, 2026

Sculptor Advisors LLC's Form ADV filing dated 2026-10-09 reports $988,960,891 in regulatory assets under management, $988,960,891 discretionary and $0 non-discretionary, 1 accounts, and 334 employees.

Assets Under Management
$989M
Employees
334
Offices
2 offices
Total Clients
<5

Associated firm names

2 names listed
  • SCULPTOR ADVISORS LLC
  • SCULPTOR CAPITAL MANAGEMENT, INC.

Leadership

3 roles identified
CCODavid C. Zeiden
CFOAnthony C. Boni
COOSteven R. Pahuskin

Advisory services offered

1 types reported
Portfolio management for pooled investment vehicles

Fee models offered

2 types reported
Asset based fees
Performance-based fees

Offices & Contact

Primary office

NEW YORK, New York, United States

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Primary office regionOther reported regions

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

New York

NEW YORKPrimary office

United Kingdom

LONDON

2 office records listed · 2 total offices reported. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$989Mas of October 9, 2026
Discretionary100.0%
$989M
100% of total RAUM100.0%
Non-discretionary0.0%
$0
0% of total RAUM0.0%
All regulatory assets under management are discretionary.

Client Coverage Demographics

Top client segmentPooled Investment Vehicles represent 100.0% of total clients.
Top client categories% of clientsClients
1
Pooled Investment Vehicles
100.0%
1

Assets under management Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$989M
Total Accounts1
10Y AUM Change+$989M

Private Funds

Private funds reported by Sculptor Advisors LLC

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Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees334
Clients per Employee0:1
10Y Employee Change-3 (-0.9%)

Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.


Ownership

Reported direct and indirect ownership ranges

Each range applies to a separate reported relationship and should not be added together.

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
SCULPTOR REAL ESTATE ADVISORS LPDirect owner · Schedule AInterest in SCULPTOR ADVISORS LLC
75%+
SCULPTOR CAPITAL MANAGEMENT, INC.Indirect owner · Schedule BInterest in SCULPTOR CAPITAL HOLDING CORPORATION
75%+
RITHM CAPITAL CORP.Indirect owner · Schedule BInterest in SCULPTOR CAPITAL MANAGEMENT, INC.
75%+
CALDER HOLDCO I LPIndirect owner · Schedule BInterest in SCULPTOR CAPITAL LP
75%+
SCULPTOR 2004 INVESTMENT PARTNERS LPIndirect owner · Schedule BInterest in SCULPTOR REAL ESTATE ADVISORS LP
50% to < 75%
SCULPTOR CAPITAL LPIndirect owner · Schedule BInterest in SCULPTOR REAL ESTATE ADVISORS LP
25% to < 50%

Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Sculptor Advisors LLC.

Reported ownership and control details

Form ADV · Filing date 2026-08-19 · Schedules A and B

12 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1SCULPTOR REAL ESTATE ADVISORS LPMANAGING MEMBERDomestic entitySCULPTOR ADVISORS LLC75% or moreCode EYesMANAGING MEMBER04/2022Schedule APDF page 97
2STEVEN EDWARD ORBUCHPRESIDENTIndividualSCULPTOR ADVISORS LLCLess than 5%Code NAYesPRESIDENT04/2022Schedule APDF page 97
3STEVEN RICHARD PAHUSKINCHIEF OPERATING OFFICERIndividualSCULPTOR ADVISORS LLCLess than 5%Code NAYesCHIEF OPERATING OFFICER07/2026Schedule APDF page 97
4ANTHONY CHARLES BONICHIEF FINANCIAL OFFICERIndividualSCULPTOR ADVISORS LLCLess than 5%Code NAYesCHIEF FINANCIAL OFFICER07/2026Schedule APDF page 97
5DAVID CRAIG ZEIDENCHIEF COMPLIANCE OFFICER, GENERAL COUNSEL AND EXECUTIVE MANAGING DIRECTORIndividualSCULPTOR ADVISORS LLCLess than 5%Code NANoCHIEF COMPLIANCE OFFICER, GENERAL COUNSEL AND EXECUTIVE MANAGING DIRECTOR07/2026Schedule APDF page 97
6SCULPTOR REAL ESTATE GP LLCGENERAL PARTNERDomestic entitySCULPTOR REAL ESTATE ADVISORS LPPercentage not specifiedCode FYesGENERAL PARTNER11/2003Schedule BPDF page 98
7SCULPTOR CAPITAL LPLIMITED PARTNERDomestic entitySCULPTOR REAL ESTATE ADVISORS LP25% to less than 50%Code CYesLIMITED PARTNER11/2003Schedule BPDF page 98
8SCULPTOR 2004 INVESTMENT PARTNERS LPLIMITED PARTNERDomestic entitySCULPTOR REAL ESTATE ADVISORS LP50% to less than 75%Code DYesLIMITED PARTNER08/2004Schedule BPDF page 98
9SCULPTOR CAPITAL HOLDING CORPORATIONGENERAL PARTNER OF SCULPTOR CAPITAL LPDomestic entitySCULPTOR CAPITAL LPPercentage not specifiedCode FYesGENERAL PARTNER OF SCULPTOR CAPITAL LP11/2007Schedule BPDF page 98
10SCULPTOR CAPITAL MANAGEMENT, INC.SOLE SHAREHOLDER OF THE GENERAL PARTNER OF SCULPTOR CAPITAL LPDomestic entitySCULPTOR CAPITAL HOLDING CORPORATION75% or moreCode EYesSOLE SHAREHOLDER OF THE GENERAL PARTNER OF SCULPTOR CAPITAL LP11/2007Schedule BPDF page 98
11RITHM CAPITAL CORP.SOLE SHAREHOLDER OF SCULPTOR CAPITAL MANAGEMENT, INC.Domestic entitySCULPTOR CAPITAL MANAGEMENT, INC.75% or moreCode EYesSOLE SHAREHOLDER OF SCULPTOR CAPITAL MANAGEMENT, INC.11/2023Schedule BPDF page 98
12CALDER HOLDCO I LPLIMITED PARTNER OF SCULPTOR CAPITAL LPDomestic entitySCULPTOR CAPITAL LP75% or moreCode EYesLIMITED PARTNER OF SCULPTOR CAPITAL LP11/2023Schedule BPDF page 98

Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.

Compliance & Disclosures

Filing dated 8/19/2026 4:31:46 PM

Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.

RIA or supervised-person involvementThe RIA reported that one or more events below involve the firm or its supervised persons.RIA responseYes
AFelonies2 Yes

In the past ten years, have you or any advisory affiliate:

  • A1Been convicted of or pleaded guilty or no contest to a felony?Yes
  • A2Been charged with a felony?Yes
BMisdemeanors2 No

In the past ten years, have you or any advisory affiliate:

  • B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
  • B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions4 Yes1 No

Has the SEC or CFTC ever:

  • C1Found you or an advisory affiliate made a false statement or omission?Yes
  • C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
  • C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
  • C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions1 Yes4 No

Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:

  • D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
  • D2Found you or an advisory affiliate violated investment-related regulations or statutes?Yes
  • D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions1 Yes3 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?No
  • E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
  • E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
  • GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No

(1) Court actions

Has a domestic or foreign court:

  • H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
  • H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
  • H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No

(2) Pending civil proceedings

  • H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 4 source blocks

Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.

criminal · block 1PDF pages 98–100
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.A. or
11.B. of Form ADV.
Criminal

Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
OCH ZIFF CAPITAL
MANAGEMENT GROUP LLC
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
OZ AFRICA MANAGEMENT GP,
LLC
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship. 
CHARGES WERE BROUGHT AGAINST OZ AFRICA MANAGEMENT GP, LLC ("OZ AFRICA") WHICH IS AN INVESTMENT-RELATED BUSINESS THAT IS A
SUBSIDIARY OF THE REGISTRANT AND OCH-ZIFF CAPITAL MANAGEMENT GROUP LLC ("OCH-ZIFF"), WHICH IS AN INVESTMENT-RELATED BUSINESS THAT
OWNS AN INTEREST IN THE REGISTRANT.
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number). 
THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK IN NEW YORK, NY (THE "COURT"). DOCKET/CASE NUMBER: 16-
CR00515 AND 16-CR-00516
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY): 
09/29/2016
 Exact
 Explanation

If not exact, provide explanation:
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related). 
OZ AFRICA AGREED TO PLEAD GUILTY TO ONE CRIMINAL COUNT, A FELONY CONSISTING OF CONSPIRACY TO VIOLATE THE ANTI-BRIBERY
PROVISIONS OF THE FCPA RELATING TO THE PAYMENTS TO GOVERNMENT OFFICIALS DESCRIBED IN MORE DETAIL IN ITEM 5 BELOW. OCH-ZIFF
WAS CHARGED UNDER THE DPA (DEFINED IN ITEM 4 BELOW) WITH FOUR CRIMINAL COUNTS, EACH A FELONY, COMPRISING TWO COUNTS OF
CONSPIRACY TO VIOLATE THE ANTI-BRIBERY PROVISIONS OF THE FCPA AND ONE COUNT EACH OF VIOLATING THE FCPA PROVISIONS RELATING
TO (I) BOOKS AND RECORDS AND (II) INTERNAL CONTROLS. AS DESCRIBED IN MORE DETAIL IN ITEM 5 BELOW, THESE CHARGES ALL RELATED TO
HEDGE FUNDS, PRIVATE EQUITY FUNDS AND INVESTMENT VEHICLES MANAGED BY THE REGISTRANT OR ITS AFFILIATES.
C.
Did any of the Charge(s) within the Event involve a felony? 
 Yes
 No
D.
Current status of the Event? 
 Pending
 On Appeal
 Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY): 
09/29/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Disposition Disclosure Detail: 
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid. 
ON SEPTEMBER 29, 2016, OZ AFRICA AGREED TO PLEAD GUILTY TO THE VIOLATION OF THE ANTI-BRIBERY PROVISIONS OF THE FCPA DESCRIBED
UNDER ITEM 3 ABOVE AND, UNDER A DEFERRED PROSECUTION AGREEMENT (THE "DPA") WITH THE DOJ AND THE U.S. ATTORNEY'S OFFICE FOR THE
EASTERN DISTRICT OF NEW YORK (TOGETHER WITH DOJ, THE "OFFICES"), THE OFFICES AGREED TO DEFER PROSECUTION OF THE CRIMINAL CHARGES
PENDING THE COMPLETION OF CERTAIN OBLIGATIONS UNDERTAKEN BY OCH-ZIFF UNDER THE DPA, INCLUDING (I) PAYMENT OF A PENALTY OF
$213,055,689; (II) RETENTION OF A COMPLIANCE MONITOR FOR 3 YEARS (SUBJECT TO EARLY TERMINATION OR EXTENSION); AND (III) CONTINUED
COOPERATION WITH GOVERNMENTAL INVESTIGATIONS. THE PENALTY WAS PAID IN FULL ON 10/7/16. PURSUANT TO THE DPA, 6 MONTHS AFTER
COMPLETION OF THOSE OBLIGATIONS AND EXPIRATION OF THE DPA, THE OFFICES WILL SEEK DISMISSAL OF THE CHARGES WITH PREJUDICE. ON
1/23/20, OCH-ZIFF CAPITAL MANAGEMENT GROUP LLC ENTERED INTO AN AMENDMENT TO ITS DPA THAT EXTENDS THE TERM OF THE DPA UNTIL 61
DAYS AFTER THE ENTRY OF A FINAL JUDGMENT BY THE EASTERN DISTRICT OF NEW YORK ( "COURT"). ON NOVEMBER 4, 2020, IN U.S. V. OZ AFRICA
MANAGEMENT GP, LLC, CR. NO. 16-515 (NGG) (EDNY) ("AFRICO MATTER"), THE COURT ORDERED RESTITUTION CONSISTENT WITH THE SETTLEMENT
AGREEMENT BETWEEN OZ AFRICA MANAGEMENT GP, LLC ("OZ AFRICA") AND FORMER SHAREHOLDERS OF AFRICO RESOURCES LTD., AND IMPOSED A
SENTENCE CONSISTENT WITH THE SETTLEMENT AGREEMENT BETWEEN OZ AFRICA AND THE OFFICES. PER THE COURT'S SENTENCE AND SETTLEMENT
AGREEMENT, OZ AFRICA PAID APPROXIMATELY $138 MILLION TO FORMER SHAREHOLDERS OF AFRICO RESOURCES LTD. ON NOVEMBER 3, 2020, THE
OFFICES AGREED TO TERMINATE THE DPA UPON CERTAIN CONDITIONS. THE DPA WAS TERMINATED SHORTLY THEREAFTER.
5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.) 
THE CHARGES RELATE TO PAYMENTS TO GOVERNMENT OFFICIALS TO OBTAIN INVESTMENTS BY A FOREIGN SOVEREIGN WEALTH FUND IN CERTAIN
HEDGE FUNDS MANAGED BY THE REGISTRANT OR ITS AFFILIATES IN 2007 AND SIMILAR PAYMENTS RELATING TO PRIVATE INVESTMENTS IN AFRICA
BETWEEN 2007 AND 2011 BY PRIVATE EQUITY FUNDS AND INVESTMENT VEHICLES MANAGED BY THE REGISTRANT OR ITS AFFILIATES. THE INDIVIDUALS
DIRECTLY RESPONSIBLE FOR MAKING THESE PAYMENTS ARE NO LONGER EMPLOYED BY THE REGISTRANT. THE INVESTIGATION RELATING TO THESE
EVENTS RESULTED IN THE GUILTY PLEA BY OZ AFRICA AND THE DPA DESCRIBED ABOVE.
regulatory · block 1SCULPTOR CAPITAL LPPDF pages 100–102
Advisory affiliate name — filed text
SCULPTOR CAPITAL LP
Regulator name — filed text
CHICAGO MERCANTILE EXCHANGE
Monetary/Fine Amount — filed text
$ 15,000.00
How was matter resolved — filed text
Settled

Action status / disposition — filed text

ON SEPTEMBER 7, 2016, A PANEL OF THE CME BUSINESS CONDUCT COMMITTEE FOUND THAT, ON JUNE 23, 2014, SCULPTOR CAPITAL VIOLATED CME RULE 538.A BY EXECUTING AN EFRP TRANSACTION IN WHICH THE RELATED POSITION TRANSACTION WAS ESTABLISHED AND OFFSET BUT THE RELATED POSITION TRANSACTION WAS NOT EXPOSED TO MARKET RISK, RESULTING IN A TRANSITORY EFRP. AN OFFER OR SETTLEMENT WAS APPROVED BY A PANEL OF THE CME BUSINESS CONDUCT COMMITTEE ON SEPTEMBER 7, 2016, IN WHICH SCULPTOR CAPITAL NEITHER ADMITTED NOR DENIED THE RULE VIOLATION ON WHICH THE PENALTY WAS BASED. PROMPTLY THEREAFTER, SCULPTOR CAPITAL PAID IN FULL A FINE OF $15,000 IN CONNECTION WITH THE SETTLEMENT.
Other filed details

Description of allegations — filed text

THE EXECUTION OF AN EXCHANGE FOR RELATED POSITION ("EFRP") TRANSACTION IN WHICH THE RELATED POSITION WAS TRANSITORY IN NATURE AND, THEREFORE, WAS NOT A BONA FIDE EFRP.

Sanction detail — filed text

A $15,000 FINE TO BE PAID BY SCULPTOR CAPITAL PROMPTLY AFTER THE SETTLEMENT WAS AGREED TO. NO PORTION OF THE FINE WAS WAIVED.
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates

If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
107913
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SCULPTOR CAPITAL LP
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CHICAGO MERCANTILE EXCHANGE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/07/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CME 15-0151-BC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Financial
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE EXECUTION OF AN EXCHANGE FOR RELATED POSITION ("EFRP") TRANSACTION IN WHICH THE RELATED POSITION WAS TRANSITORY IN NATURE
AND, THEREFORE, WAS NOT A BONA FIDE EFRP.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:

Settled
11. Resolution Date (MM/DD/YYYY):
09/07/2016
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 15,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
A $15,000 FINE TO BE PAID BY SCULPTOR CAPITAL PROMPTLY AFTER THE SETTLEMENT WAS AGREED TO. NO PORTION OF THE FINE WAS
WAIVED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON SEPTEMBER 7, 2016, A PANEL OF THE CME BUSINESS CONDUCT COMMITTEE FOUND THAT, ON JUNE 23, 2014, SCULPTOR CAPITAL VIOLATED CME
RULE 538.A BY EXECUTING AN EFRP TRANSACTION IN WHICH THE RELATED POSITION TRANSACTION WAS ESTABLISHED AND OFFSET BUT THE RELATED
POSITION TRANSACTION WAS NOT EXPOSED TO MARKET RISK, RESULTING IN A TRANSITORY EFRP. AN OFFER OR SETTLEMENT WAS APPROVED BY A
PANEL OF THE CME BUSINESS CONDUCT COMMITTEE ON SEPTEMBER 7, 2016, IN WHICH SCULPTOR CAPITAL NEITHER ADMITTED NOR DENIED THE
RULE VIOLATION ON WHICH THE PENALTY WAS BASED. PROMPTLY THEREAFTER, SCULPTOR CAPITAL PAID IN FULL A FINE OF $15,000 IN CONNECTION
WITH THE SETTLEMENT.
regulatory · block 2PDF pages 102–104
How was matter resolved — filed text
Consent

Action status / disposition — filed text

IN SETTLEMENT OF THIS MATTER, THE REGISTRANT, OCH-ZIFF, OCH AND FRANK AGREED TO THE ISSUANCE OF THE ORDER WHICH MADE THE FINDINGS DESCRIBED ABOVE IN ITEM 7 AND PROVIDED FOR THE SANCTIONS DESCRIBED ABOVE IN ITEM 12. THE ORDER WAS ISSUED BY THE SEC ON SEPTEMBER 29, 2016 AND IS FINAL. AS DESCRIBED ABOVE IN ITEM 12, THE ORDER PROVIDED THAT THE AMOUNT OF CIVIL PENALTIES, IF ANY, IMPOSED AGAINST MR. FRANK WILL BE DETERMINED IN FUTURE RELATED SEC PROCEEDINGS. ON MARCH 16, 2021, THE SEC ORDERED FRANK TO PAY $35,000 IN CIVIL PENALTIES. THE MATTER IS NOW CLOSED.
Other filed details

Description of allegations — filed text

THE SEC ENTERED A CEASE-AND-DESIST ORDER BY CONSENT AGAINST THE REGISTRANT, OCH-ZIFF, AND DANIEL S. OCH ("OCH") AND JOEL M. FRANK ("FRANK"), OCH-ZIFF'S CHIEF EXECUTIVE OFFICER AND CHIEF FINANCIAL OFFICER, RESPECTIVELY, WITHOUT EITHER OF THE INDIVIDUAL RESPONDENTS' ADMITTING OR DENYING THE FINDINGS IN THE ORDER. THE ORDER RELATED TO PAYMENTS TO GOVERNMENT OFFICIALS TO OBTAIN INVESTMENTS BY A FOREIGN SOVEREIGN WEALTH FUND IN CERTAIN HEDGE FUNDS MANAGED BY THE REGISTRANT OR ITS AFFILIATES IN 2007 AND SIMILAR PAYMENTS RELATING TO PRIVATE INVESTMENTS IN AFRICA BETWEEN 2007 AND 2011 BY PRIVATE EQUITY FUNDS AND INVESTMENT VEHICLES MANAGED BY THE REGISTRANT OR ITS AFFILIATES. THE INDIVIDUALS DIRECTLY RESPONSIBLE FOR MAKING THESE PAYMENTS ARE NO LONGER EMPLOYED BY THE REGISTRANT. THE ORDER FINDS THAT (I) OCH-ZIFF VIOLATED SECTIONS 13(B)(2)(A), 13(B)(2)(B) AND 30A OF THE EXCHANGE ACT, AND (II) THE REGISTRANT VIOLATED SECTIONS 206(1), 206(2) AND 206(4) AND RULE 206(4)-8 OF THE ADVISERS ACT. IN ADDITION, THE ORDER STATES THAT FRANK WAS A CAUSE OF VIOLATIONS OF SECTIONS 13(B)(2)(A) AND 13(B)(2)(B) OF THE EXCHANGE ACT AND THAT OCH WAS A CAUSE OF VIOLATIONS OF SECTION 13(B)(2)(A) OF THE EXCHANGE ACT. THE SAME EVENTS GAVE RISE TO THE GUILTY PLEA AND DEFERRED PROSECUTION AGREEMENT (THE "DPA") DESCRIBED IN THE REGISTRANT'S CRIMINAL DISCLOSURE REPORTING PAGES.

Sanction detail — filed text

THE ORDER CENSURED OCH-ZIFF AND THE REGISTRANT PURSUANT TO SECTION 21C OF THE EXCHANGE ACT AND SECTIONS 203(E) AND (K) OF THE ADVISERS ACT AND REQUIRES (1) OCH-ZIFF TO CEASE AND DESIST FROM COMMITTING OR CAUSING VIOLATIONS OF SECTIONS 13(B)(2)(A), 13(B)(2)(B) AND 30A OF THE EXCHANGE ACT, (2) THE REGISTRANT TO CEASE AND DESIST FROM COMMITTING OR CAUSING VIOLATIONS OF SECTIONS 206(1), 206(2) AND 206(4) AND RULE 206(4)-8 OF THE ADVISERS ACT, (3) FRANK TO CEASE AND DESIST FROM COMMITTING OR CAUSING VIOLATIONS OF SECTIONS 13(B)(2)(A) AND 13(B)(2)(B) OF THE EXCHANGE ACT, AND (4) OCH TO CEASE AND DESIST FROM COMMITTING OR CAUSING VIOLATIONS OF SECTION 13(B)(2)(A) OF THE EXCHANGE ACT. IN ADDITION, THE ORDER REQUIRES OCH-ZIFF AND THE REGISTRANT TO PAY DISGORGEMENT OF $173,186,178 AND PREJUDGMENT INTEREST OF $25,858,989, AND REQUIRES OCH TO PAY DISGORGEMENT OF $1,900,000 AND PREJUDGMENT INTEREST OF $273,718. THESE AMOUNTS WERE PAID IN FULL ON OCTOBER 11, 2016. A ONE-TIME $173,186,178 PENALTY WAS DEEMED SATISFIED BASED UPON OCH-ZIFF'S PAYMENT OF THE PENALTY IN THE AMOUNT OF $213,055,689 PURSUANT TO THE DPA, AS DESCRIBED ABOVE. THE AMOUNT OF CIVIL PENALTIES, IF ANY, IMPOSED AGAINST MR. FRANK WILL BE DETERMINED IN FUTURE RELATED SEC PROCEEDINGS. UNDER THE SETTLEMENT, OCH-ZIFF AND THE REGISTRANT UNDERTAKE TO IMPLEMENT ENHANCED INTERNAL ACCOUNTING CONTROLS AND POLICIES, TO SEPARATE THE CHIEF COMPLIANCE OFFICER FROM OTHER OFFICER POSITIONS AND TO ENGAGE AN INDEPENDENT COMPLIANCE MONITOR FOR THREE YEARS, SUBJECT TO EARLY TERMINATION OR EXTENSION. OCH-ZIFF, THE REGISTRANT, OCH AND FRANK UNDERTAKE TO COOPERATE IN FUTURE RELATED SEC PROCEEDINGS.
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
107913
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No

Name:
SCULPTOR CAPITAL LP
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
OZ AFRICA MANAGEMENT GP,
LLC
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
OCH ZIFF CAPITAL
MANAGEMENT GROUP LLC
(For individuals, Last, First,
Middle)
CRD
Number:
1078046
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
OCH, DANIEL, SAUL
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CENSURE, DISGORGEMENT AND UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
09/26/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ADMINISTRATIVE PROCEEDING FILE NO. 3-17595
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT APPLICABLE
6.
Principal Product Type:

Direct Investment(s) - DPP & LP Interest(s)
Other Product Types: 
DIRECT INVESTMENTS - DPP & LP INTERESTS OTHER - HEDGE FUNDS AND PRIVATE EQUITY FUNDS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEC ENTERED A CEASE-AND-DESIST ORDER BY CONSENT AGAINST THE REGISTRANT, OCH-ZIFF, AND DANIEL S. OCH ("OCH") AND JOEL M. FRANK
("FRANK"), OCH-ZIFF'S CHIEF EXECUTIVE OFFICER AND CHIEF FINANCIAL OFFICER, RESPECTIVELY, WITHOUT EITHER OF THE INDIVIDUAL
RESPONDENTS' ADMITTING OR DENYING THE FINDINGS IN THE ORDER. THE ORDER RELATED TO PAYMENTS TO GOVERNMENT OFFICIALS TO OBTAIN
INVESTMENTS BY A FOREIGN SOVEREIGN WEALTH FUND IN CERTAIN HEDGE FUNDS MANAGED BY THE REGISTRANT OR ITS AFFILIATES IN 2007 AND
SIMILAR PAYMENTS RELATING TO PRIVATE INVESTMENTS IN AFRICA BETWEEN 2007 AND 2011 BY PRIVATE EQUITY FUNDS AND INVESTMENT VEHICLES
MANAGED BY THE REGISTRANT OR ITS AFFILIATES. THE INDIVIDUALS DIRECTLY RESPONSIBLE FOR MAKING THESE PAYMENTS ARE NO LONGER
EMPLOYED BY THE REGISTRANT. THE ORDER FINDS THAT (I) OCH-ZIFF VIOLATED SECTIONS 13(B)(2)(A), 13(B)(2)(B) AND 30A OF THE EXCHANGE ACT,
AND (II) THE REGISTRANT VIOLATED SECTIONS 206(1), 206(2) AND 206(4) AND RULE 206(4)-8 OF THE ADVISERS ACT. IN ADDITION, THE ORDER
STATES THAT FRANK WAS A CAUSE OF VIOLATIONS OF SECTIONS 13(B)(2)(A) AND 13(B)(2)(B) OF THE EXCHANGE ACT AND THAT OCH WAS A CAUSE OF
VIOLATIONS OF SECTION 13(B)(2)(A) OF THE EXCHANGE ACT. THE SAME EVENTS GAVE RISE TO THE GUILTY PLEA AND DEFERRED PROSECUTION
AGREEMENT (THE "DPA") DESCRIBED IN THE REGISTRANT'S CRIMINAL DISCLOSURE REPORTING PAGES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
09/29/2016
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE ORDER CENSURED OCH-ZIFF AND THE REGISTRANT PURSUANT TO SECTION 21C OF THE EXCHANGE ACT AND SECTIONS 203(E) AND (K) OF
THE ADVISERS ACT AND REQUIRES (1) OCH-ZIFF TO CEASE AND DESIST FROM COMMITTING OR CAUSING VIOLATIONS OF SECTIONS 13(B)(2)(A),
13(B)(2)(B) AND 30A OF THE EXCHANGE ACT, (2) THE REGISTRANT TO CEASE AND DESIST FROM COMMITTING OR CAUSING VIOLATIONS OF
SECTIONS 206(1), 206(2) AND 206(4) AND RULE 206(4)-8 OF THE ADVISERS ACT, (3) FRANK TO CEASE AND DESIST FROM COMMITTING OR
CAUSING VIOLATIONS OF SECTIONS 13(B)(2)(A) AND 13(B)(2)(B) OF THE EXCHANGE ACT, AND (4) OCH TO CEASE AND DESIST FROM
COMMITTING OR CAUSING VIOLATIONS OF SECTION 13(B)(2)(A) OF THE EXCHANGE ACT. IN ADDITION, THE ORDER REQUIRES OCH-ZIFF AND THE
REGISTRANT TO PAY DISGORGEMENT OF $173,186,178 AND PREJUDGMENT INTEREST OF $25,858,989, AND REQUIRES OCH TO PAY
DISGORGEMENT OF $1,900,000 AND PREJUDGMENT INTEREST OF $273,718. THESE AMOUNTS WERE PAID IN FULL ON OCTOBER 11, 2016. A
ONE-TIME $173,186,178 PENALTY WAS DEEMED SATISFIED BASED UPON OCH-ZIFF'S PAYMENT OF THE PENALTY IN THE AMOUNT OF
$213,055,689 PURSUANT TO THE DPA, AS DESCRIBED ABOVE. THE AMOUNT OF CIVIL PENALTIES, IF ANY, IMPOSED AGAINST MR. FRANK WILL BE
DETERMINED IN FUTURE RELATED SEC PROCEEDINGS. UNDER THE SETTLEMENT, OCH-ZIFF AND THE REGISTRANT UNDERTAKE TO IMPLEMENT
ENHANCED INTERNAL ACCOUNTING CONTROLS AND POLICIES, TO SEPARATE THE CHIEF COMPLIANCE OFFICER FROM OTHER OFFICER
POSITIONS AND TO ENGAGE AN INDEPENDENT COMPLIANCE MONITOR FOR THREE YEARS, SUBJECT TO EARLY TERMINATION OR EXTENSION.
OCH-ZIFF, THE REGISTRANT, OCH AND FRANK UNDERTAKE TO COOPERATE IN FUTURE RELATED SEC PROCEEDINGS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN SETTLEMENT OF THIS MATTER, THE REGISTRANT, OCH-ZIFF, OCH AND FRANK AGREED TO THE ISSUANCE OF THE ORDER WHICH MADE THE FINDINGS
DESCRIBED ABOVE IN ITEM 7 AND PROVIDED FOR THE SANCTIONS DESCRIBED ABOVE IN ITEM 12. THE ORDER WAS ISSUED BY THE SEC ON
SEPTEMBER 29, 2016 AND IS FINAL. AS DESCRIBED ABOVE IN ITEM 12, THE ORDER PROVIDED THAT THE AMOUNT OF CIVIL PENALTIES, IF ANY,
IMPOSED AGAINST MR. FRANK WILL BE DETERMINED IN FUTURE RELATED SEC PROCEEDINGS. ON MARCH 16, 2021, THE SEC ORDERED FRANK TO PAY
$35,000 IN CIVIL PENALTIES. THE MATTER IS NOW CLOSED.
regulatory · block 3PDF pages 105–107
Regulator name — filed text
THELLENIC CAPITAL MARKET COMMISSION ("HCMC"), THE GREEK FINANCIAL SERVICES REGULATOR.
Monetary/Fine Amount — filed text
$ 260,000.00
How was matter resolved — filed text
Decision

Action status / disposition — filed text

ON MAY 30, 2018, 11 OF THE 12 FUNDS THAT PARTICIPATED IN THE EUROBANK PLACEMENT WERE FINED 324,000 EURO, BUT EXPECT TO PAY A TOTAL FINE OF 260,000 EURO DUE TO THE SETTLEMENT DISCOUNT. THE FIRM DOES NOT EXPECT THE 12TH FUND TO BE FINED FOR THE REASON INDICATED ABOVE. THE FIRM NOTIFIED THE HCMC OF ITS DECISION NOT TO APPEAL THE FINE. WHILE WE CONTINUE TO STRONGLY BELIEVE THE RELEVANT TRADES WERE FULLY COMPLIANT WITH THE EU SSR, THE FIRM'S DECISION TO FOREGO THE OPPORTUNITY TO APPEAL AND AGREE TO PAY THE FINE ASSOCIATED WITH THE ALLEGED VIOLATION WILL (I) ALLOW THE FIRM TO AVOID THE LEGAL COST OF PURSUING AN APPEAL AND (II) ALLOW THE FIRM TO TAKE ADVANTAGE OF A 20% DISCOUNT ON THE FINE OFFERED BY THE HCMC TO ANY PARTY WHICH AGREES TO ACCEPT THEIR DECISION. THE FIRM AWAITS PAYMENT INSTRUCTIONS FROM THE HCMC OR RELEVANT AUTHORITY IN GREECE IN ORDER TO PAY THE FINE. THE FIRM'S CLIENTS WILL NOT BEAR ANY COST ASSOCIATED WITH THE FINE LEVIED BY THE HCMC.
Other filed details

Description of allegations — filed text

IN APRIL 2014, OZME, A RELYING ADVISER OF OZ MANAGEMENT LP (TOGETHER WITH OZME, THE "FIRM") SUBSCRIBED FOR A TOTAL OF 24,000,000 SHARES OF A SECONDARY OFFERING OF EUROBANK ERGASIAS S.A., A GREEK LISTED ISSUER ("EUROBANK"). THE TRADE DATE FOR THIS TRANSACTION WAS APRIL 30, 2014, WITH A SETTLEMENT DATE OF MAY 8, 2014, AND THE EUROBANK SHARES STARTED TRADING IN THE MARKET ON MAY 9, 2014. OZME SUBSEQUENTLY SOLD SOME OF THE LONG POSITION IN THE EUROBANK SHARES, WITH A TRADE DATE OF MAY 6, 2014 AND A SETTLEMENT DATEOF MAY 9, 2014 (THE "SALE TRANSACTION"). OZME TIMELY DELIVERED THE SHARES ON MAY 9, 2014. THE HCMC ALLEGES THAT THE SALE TRANSACTION AMOUNTED TO AN UNCOVERED SHORT SALE IN BREACH OF THE EU SSR.

Sanction detail — filed text

ON MAY 30, 2018, 11 OF THE 12 FUNDS THAT PARTICIPATED IN THE EUROBANK PLACEMENT WERE FINED 324,000 EURO, BUT EXPECT TO PAY A TOTAL FINE OF 260,000 EURO DUE TO THE SETTLEMENT DISCOUNT. THE FIRM DOES NOT EXPECT THE 12TH FUND TO BE FINED FOR THE REASON INDICATED ABOVE. THE FIRM NOTIFIED THE HCMC OF ITS DECISION NOT TO APPEAL THE FINE. WHILE WE CONTINUE TO STRONGLY BELIEVE THE RELEVANT TRADES WERE FULLY COMPLIANT WITH THE EU SSR, THE FIRM'S DECISION TO FOREGO THE OPPORTUNITY TO APPEAL AND AGREE TO PAY THE FINE ASSOCIATED WITH THE ALLEGED VIOLATION WILL (I) ALLOW THE FIRM TO AVOID THE LEGAL COST OF PURSUING AN APPEAL AND (II) ALLOW THE FIRM TO TAKE ADVANTAGE OF A 20% DISCOUNT ON THE FINE OFFERED BY THE HCMC TO ANY PARTY WHICH AGREES TO ACCEPT THEIR DECISION. THE FIRM AWAITS PAYMENT INSTRUCTIONS FROM THE HCMC OR RELEVANT AUTHORITY IN GREECE IN ORDER TO PAY THE FINE. THE FIRM'S CLIENTS WILL NOT BEAR ANY COST ASSOCIATED WITH THE FINE LEVIED BY THE HCMC.
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
107913
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SCULPTOR CAPITAL LP
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
OCH-ZIFF MANAGEMENT
EUROPE LIMITED
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:

SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
THELLENIC CAPITAL MARKET COMMISSION ("HCMC"), THE GREEK FINANCIAL SERVICES REGULATOR.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/13/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
135/15.1.2015, 124/15.1.2015 AND 1027/20.3.2015
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT APPLICABLE
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN APRIL 2014, OZME, A RELYING ADVISER OF OZ MANAGEMENT LP (TOGETHER WITH OZME, THE "FIRM") SUBSCRIBED FOR A TOTAL OF 24,000,000
SHARES OF A SECONDARY OFFERING OF EUROBANK ERGASIAS S.A., A GREEK LISTED ISSUER ("EUROBANK"). THE TRADE DATE FOR THIS TRANSACTION
WAS APRIL 30, 2014, WITH A SETTLEMENT DATE OF MAY 8, 2014, AND THE EUROBANK SHARES STARTED TRADING IN THE MARKET ON MAY 9, 2014.
OZME SUBSEQUENTLY SOLD SOME OF THE LONG POSITION IN THE EUROBANK SHARES, WITH A TRADE DATE OF MAY 6, 2014 AND A SETTLEMENT
DATEOF MAY 9, 2014 (THE "SALE TRANSACTION"). OZME TIMELY DELIVERED THE SHARES ON MAY 9, 2014. THE HCMC ALLEGES THAT THE SALE
TRANSACTION AMOUNTED TO AN UNCOVERED SHORT SALE IN BREACH OF THE EU SSR.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
05/30/2018
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 260,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
ON MAY 30, 2018, 11 OF THE 12 FUNDS THAT PARTICIPATED IN THE EUROBANK PLACEMENT WERE FINED 324,000 EURO, BUT EXPECT TO PAY A
TOTAL FINE OF 260,000 EURO DUE TO THE SETTLEMENT DISCOUNT. THE FIRM DOES NOT EXPECT THE 12TH FUND TO BE FINED FOR THE REASON
INDICATED ABOVE. THE FIRM NOTIFIED THE HCMC OF ITS DECISION NOT TO APPEAL THE FINE. WHILE WE CONTINUE TO STRONGLY BELIEVE THE
RELEVANT TRADES WERE FULLY COMPLIANT WITH THE EU SSR, THE FIRM'S DECISION TO FOREGO THE OPPORTUNITY TO APPEAL AND AGREE TO
PAY THE FINE ASSOCIATED WITH THE ALLEGED VIOLATION WILL (I) ALLOW THE FIRM TO AVOID THE LEGAL COST OF PURSUING AN APPEAL AND
(II) ALLOW THE FIRM TO TAKE ADVANTAGE OF A 20% DISCOUNT ON THE FINE OFFERED BY THE HCMC TO ANY PARTY WHICH AGREES TO ACCEPT
THEIR DECISION. THE FIRM AWAITS PAYMENT INSTRUCTIONS FROM THE HCMC OR RELEVANT AUTHORITY IN GREECE IN ORDER TO PAY THE FINE.
THE FIRM'S CLIENTS WILL NOT BEAR ANY COST ASSOCIATED WITH THE FINE LEVIED BY THE HCMC.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON MAY 30, 2018, 11 OF THE 12 FUNDS THAT PARTICIPATED IN THE EUROBANK PLACEMENT WERE FINED 324,000 EURO, BUT EXPECT TO PAY A TOTAL
FINE OF 260,000 EURO DUE TO THE SETTLEMENT DISCOUNT. THE FIRM DOES NOT EXPECT THE 12TH FUND TO BE FINED FOR THE REASON INDICATED
ABOVE. THE FIRM NOTIFIED THE HCMC OF ITS DECISION NOT TO APPEAL THE FINE. WHILE WE CONTINUE TO STRONGLY BELIEVE THE RELEVANT
TRADES WERE FULLY COMPLIANT WITH THE EU SSR, THE FIRM'S DECISION TO FOREGO THE OPPORTUNITY TO APPEAL AND AGREE TO PAY THE FINE
ASSOCIATED WITH THE ALLEGED VIOLATION WILL (I) ALLOW THE FIRM TO AVOID THE LEGAL COST OF PURSUING AN APPEAL AND (II) ALLOW THE FIRM
TO TAKE ADVANTAGE OF A 20% DISCOUNT ON THE FINE OFFERED BY THE HCMC TO ANY PARTY WHICH AGREES TO ACCEPT THEIR DECISION. THE FIRM
AWAITS PAYMENT INSTRUCTIONS FROM THE HCMC OR RELEVANT AUTHORITY IN GREECE IN ORDER TO PAY THE FINE. THE FIRM'S CLIENTS WILL NOT
BEAR ANY COST ASSOCIATED WITH THE FINE LEVIED BY THE HCMC.

* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.