Stony Creek GRC

Executive-level compliance expertise
for alternative investments

Delivered with the depth of an attorney, the experience of a CCO, and the accountability of a partner. Built exclusively for hedge funds, private equity, and their allocators.

Schedule a Conversation Our Services
20+
Years in Hedge Fund
& Private Equity
J.D.
Attorney & CCO
Dual Expertise
100%
Direct Principal Access
No Junior Handoffs
Stony Creek GRC
About the Firm

Boutique. Executive. Specialized.

Stony Creek GRC is a boutique advisory firm founded by Daniel Dwyer, a seasoned attorney and Chief Compliance Officer with over two decades of experience inside hedge funds and private equity firms.

SCGRC serves two distinct client types: alternative investment managers who need a trusted compliance partner, and institutional allocators and family offices who need rigorous operational due diligence on the funds they evaluate. This dual-sided model gives SCGRC a uniquely comprehensive view of the alternative investments ecosystem.

For regulated enterprises facing significant change, SCGRC also provides end-to-end LGRC transformation — redesigning Legal, Governance, Risk & Compliance functions from operating model through hands-on execution.

Attorney-Trained CCO Legal judgment applied to compliance — reading SEC guidance and enforcement actions the way an attorney reads case law, combined with 20+ years of hands-on CCO experience.
Alternatives-Only Focus Built exclusively for hedge funds, private equity, family offices, and their institutional allocators.
Direct Principal Engagement Every engagement is led by Daniel Dwyer. No junior staff, no handoffs, no diluted expertise.
SEC Examination Ready Deep familiarity with Form ADV, Form PF, the SEC Marketing Rule, Reg S-P, and current enforcement priorities.
Digital Transformation & Legal Technology Practical experience leveraging AI and legal technology to modernize compliance functions — increasing productivity, reducing manual workload, and scaling governance infrastructure.
LGRC Operating Model Design End-to-end transformation of legal, governance, risk, and compliance functions — including org redesign, process optimization, and operating model build for global regulated enterprises.
About the Founder

Daniel Dwyer — Attorney, CCO,
and Compliance Architect

Daniel Dwyer — Founder, Stony Creek GRC
Daniel Dwyer
Founder & Principal  ·  Attorney-Trained CCO

Daniel Dwyer is the founder of Stony Creek GRC and one of the few compliance practitioners in the alternative investments space who combines active licensure as an attorney with more than two decades of hands-on CCO experience inside hedge funds and private equity firms.

Most recently, Daniel served as Managing Director, Chief Compliance Officer and Counsel at Portfolio Advisors — a global private markets firm with $85 billion in AUM — where he led end-to-end design and transformation of the firm's LGRC function, scaling infrastructure alongside AUM growth from ~$20B to $85B over 12 years. He served as primary legal and regulatory advisor to founders, CEO, and executive committee, chaired the Compliance Committee, and directed regulatory strategy across SEC, CFTC, FINRA, FinCEN, OFAC, and four international regulators simultaneously.

Prior to Portfolio Advisors, Daniel served as General Counsel and CCO at Touradji Capital Management (commodities-focused RIA), Sursum Capital Management, and AM Investment Partners — managing governance and compliance programs across commodities, long volatility, and long/short equity strategies, including international licensing and registration in Hong Kong, Dubai, and Japan.

Beyond traditional compliance, Daniel has led large-scale LGRC transformation engagements — redesigning operating models, rationalizing governance structures, and driving digital transformation within legal and compliance functions. This includes serving as a member of Portfolio Advisors' AI Committee, leading the design and build of an enterprise-wide AI governance programme and embedding cybersecurity and digital privacy obligations into the firm's compliance framework.

Daniel founded SCGRC to bring that depth of executive-level, integrated expertise to alternative investment managers and regulated enterprises who need a true compliance and governance partner — not a compliance vendor.

Most Recent Role
Managing Director, CCO & Counsel
Portfolio Advisors ($85B AUM)
Experience
20+ years · Hedge Funds, PE,
Credit & LGRC Transformation
Legal Credentials
J.D., Willamette University
CT & NY Bar
Education
B.A. American History, Connecticut College
Cert. Comparative Law, East China Univ.
Regulatory Jurisdictions
SEC CFTC FinCEN / OFAC FINRA MAS — Singapore SFC — Hong Kong DFSA — Dubai FINMA — Switzerland CSA — Canada FCA — United Kingdom
Our Model

Two Sides of the Same Ecosystem

SCGRC's dual-sided model creates a self-reinforcing advantage: ODD work for allocators builds deep insight into what institutional investors demand — and that intelligence directly informs how we build compliance programs for funds that want to attract and retain them.

For Allocators
Operational Due Diligence

Independent ODD assessments for pension funds, endowments, family offices, and fund-of-funds evaluating alternative investment managers. We assess governance, risk controls, compliance infrastructure, and operational integrity — giving allocators the independent view they need to invest with confidence.

For Funds
Outsourced Compliance Leadership

CCO of record, compliance program design, SEC registration, and ongoing regulatory oversight for hedge funds and private equity managers. We build programs that don't just satisfy regulators — they also satisfy the increasingly sophisticated ODD scrutiny of institutional allocators.

Services

What We Do

Five core service lines, each grounded in two decades of hands-on experience at the intersection of law, compliance, and alternative investments.

01
Outsourced Chief Compliance Officer

Serve as designated CCO of record for SEC-registered investment advisers. Full compliance program management, annual reviews, regulatory filings, and ongoing monitoring — all backed by legal training and two decades of CCO experience.

CCO of Record Annual Reviews SEC Filings Ongoing Monitoring
02
Operational Due Diligence (ODD)

Independent ODD assessments for allocators evaluating hedge funds and private equity managers. Full-spectrum coverage: governance, regulatory infrastructure, risk controls, cybersecurity, and operational integrity — with initial and ongoing monitoring programs.

Governance Review Risk Controls Cybersecurity Operational Integrity
Learn More →
03
General Compliance Services

Comprehensive compliance services for registered investment advisers — from SEC registration and program buildout to annual reviews, marketing rule compliance, AML/KYC, examination preparation, and AI governance.

Form ADV Marketing Rule AML/KYC Exam Prep AI Governance
Learn More →
04
LGRC Transformation

End-to-end transformation of Legal, Governance, Risk & Compliance functions for regulated enterprises. Operating model design, org restructure, process redesign, and hands-on implementation — led by a senior operator who has done this work at scale.

Operating Model Org Design Process Redesign Digital Transformation
Learn More →
05
SEC Registration & RIA Formation

End-to-end support for investment advisers registering with the SEC. Form ADV drafting, compliance manual, Code of Ethics, IARD filing, and post-registration implementation.

Form ADV IARD Filing Compliance Manual Code of Ethics
Operational Due Diligence

Independent. Rigorous. Built for How Allocators Actually Work.

Allocators today face a more demanding operational environment than ever before. Regulatory scrutiny of managers has intensified, investor expectations around risk governance have risen sharply, and the consequences of operational failures — fraud, valuation manipulation, cybersecurity breaches — have never been more visible. Operational due diligence is no longer a checkbox. It's a core investment discipline.

Stony Creek GRC provides independent ODD services to institutional investors, family offices, funds of funds, and advisory platforms allocating across alternative investment strategies — private equity, private credit, hedge funds, real assets, and emerging managers.

How We Start: Advisory, Not Checklist

Every engagement begins with a conversation, not a questionnaire. We work with you in an advisory capacity to scope the assessment — determining which managers warrant review, at what depth, and against what specific concerns or risk tolerances. Whether you're conducting initial pre-commitment diligence on an emerging manager or refreshing an existing relationship, the right scope makes the work meaningful. We don't run a standard checklist. We design the assessment around what you actually need to know.

What We Assess
Governance & Organizational Structure
Ownership structure, key person risk, succession planning, and independence of oversight functions.
Regulatory & Compliance Infrastructure
Registration status, compliance program design, regulatory history, examination findings, and CCO tenure and authority.
Risk Management Framework
Investment and operational risk controls, valuation policies, liquidity governance, and side pocket practices.
Finance & Fund Administration
Administrator independence, NAV calculation controls, audit quality and relationships, and fee and expense practices.
Cybersecurity & Data Governance
IT infrastructure, incident response protocols, third-party vendor risk, and alignment with SEC cybersecurity rules and Reg S-P.
Legal & Regulatory Documents
Fund documents, side letters, investor rights, material contract review, and regulatory filing accuracy.
Accountable to Your Timeline
Initial Assessments
Pre-Commitment ODD
ODD that misses a closing or arrives after a commitment is made didn't help anyone. We manage every engagement against your timeline — surfacing material findings and red flags as they emerge, not just at the end of the process. Interim updates, early escalation, and a written ODD report with findings and follow-up items mean you're never waiting on us when a decision needs to be made.
Portfolio Monitoring
Ongoing ODD Programs
Continuous monitoring throughout the life of an investment — tracking material changes in personnel, regulatory status, risk controls, and operational infrastructure. For select institutional clients, we also provide co-sourced ODD support, working alongside internal teams using your procedures and templates, or supplementing capacity during periods of high deal flow.

Most ODD providers assess funds from the outside in. We've worked from the inside out. Having built, run, and transformed the compliance and legal functions that ODD assessors examine, we know what a well-constructed governance program looks like, what a CCO with real authority — rather than just a title — looks like, and which policies exist on paper but aren't followed. That inside-operator perspective is something an investigative firm or a career allocator can't replicate. It's the core of what makes SCGRC's ODD different.

General Compliance Services

Compliance That Works With Your Business.

No two funds are built the same way. At Stony Creek GRC, we don't apply a template — we design compliance solutions that fit your structure, your strategy, and your regulatory footprint. We work with registered investment advisers, private fund managers, and alternative investment firms navigating SEC, CFTC, FINRA, FinCEN, and multi-jurisdictional requirements.

Outsourced CCO
For funds that need senior compliance leadership without a full-time hire, we serve as CCO of record — providing active, accountable oversight rather than a name on a form. We attend committee meetings, engage regulators, author your compliance calendar, and stand behind the program we design.
Compliance Program Design & Buildout
Whether you're registering for the first time or rebuilding a program that's outgrown its original design, we draft the policies, procedures, and governance frameworks your firm needs — calibrated to what regulators actually expect, not boilerplate.
Annual Reviews & Ongoing Monitoring
Rule 206(4)-7 requires a documented annual review of your compliance program. We conduct rigorous, substantive reviews — forensic testing, gap analysis, and written findings — not box-checking exercises. Ongoing monitoring keeps your program current as your firm and the regulatory environment evolve.
Examination Preparation & Regulatory Response
We prepare firms for SEC examinations before they happen, and manage the response process when regulators are at the door — coordinating document production, preparing personnel, and engaging directly with examiners. Backed by experience managing multi-agency examination tracks across SEC, CFTC, FINRA, and FinCEN simultaneously.
Marketing Rule & Disclosure Review
Pre-publication review of fund materials under the SEC's 2022 marketing rule — performance presentations, pitch books, DDQs, and investor communications. We also handle regulatory filings: Form ADV, Form PF, Section 13, and blue sky compliance.
AML/KYC, Sanctions & AI Governance
Program design and ongoing monitoring for FinCEN/AML and OFAC obligations, including investor onboarding workflows and screening protocols. As funds deploy AI tools across investment, operations, and compliance functions, we also design the policy frameworks, risk assessment protocols, and use-case governance structures regulators will expect to see.
LGRC Transformation

When Incremental Isn't Enough.

Some compliance and legal functions need more than an annual tune-up. They need to be rebuilt. Whether a firm has outgrown its original infrastructure, is integrating an acquisition, preparing for a regulatory examination of real consequence, or simply recognizes that its Legal, Governance, Risk & Compliance function was never designed — it evolved — Stony Creek GRC provides the senior operator to lead the transformation from the ground up.

This is not a consulting engagement that produces a report. It's hands-on redesign and implementation, led by a principal with 20+ years of direct experience doing exactly this work inside regulated firms at scale.

What End-to-End Transformation Means
01
Function Design & Operating Model
Assessment of current state — structure, roles, reporting lines, committee governance, policy architecture — and design of the future-state function the firm actually needs. Includes organizational design, mandate clarity, and the governance frameworks that make the function work.
02
Core Process Redesign
AML/KYC, conflicts of interest, valuations, disclosures, outside counsel management, and regulatory filings — mapped, rationalized, and rebuilt with scalable workflows and documentation standards that hold up under examination.
03
Regulatory Infrastructure Build
Multi-regulator environments require deliberate design. We build the full infrastructure — policies, procedures, monitoring protocols, training programmes, exam readiness frameworks — across SEC, CFTC, FINRA, FinCEN, OFAC, and applicable international regimes.
04
Digital & Legal Tech Integration
Deployment of AI and legal technology tools to digitize compliance functions, increase team productivity, and embed risk management into firm culture as a proactive discipline — including AI governance frameworks and cybersecurity/privacy compliance integration.
05
Stakeholder Engagement & Change Management
Transformation programmes succeed or fail at the top. We engage General Counsel, CFO, and Board-level stakeholders directly — authoring committee governance materials, leading working groups, and managing the change process across the organisation.
06
Globally Aligned, US-Led Delivery
Delivery of a globally coherent model with strong emphasis on US regulatory environment — drawing on direct experience operating across US, UK, Hong Kong, Switzerland, Dubai, and Japan within complex, multi-jurisdictional regulatory frameworks.
Who This Engagement Is For
This engagement is suited to firms undergoing significant change: rapid AUM growth, geographic expansion, a first institutional capital raise, regulatory remediation, or leadership transition in the legal or compliance function. It is also appropriate for firms that have never had a dedicated LGRC build — where the function was run by the founder, a generalist, or outside counsel — and where the gap between current state and institutional standard has become a liability.
The Stony Creek GRC Difference
Daniel Dwyer built and transformed the LGRC function at Portfolio Advisors from approximately $20B to $85B AUM over 12 years — designing the operating model, chairing the Compliance Committee, directing multi-agency regulatory strategy across six regulators simultaneously, and leading the firm's enterprise AI governance programme. He has held concurrent GC/CCO responsibility across five regulated entities over a 20-year career, with direct accountability to founders, boards, and regulators at each. He does not subcontract this work. He does it.
Clients

Who We Serve

SCGRC works exclusively within the alternative investments ecosystem — on both sides of the manager-allocator relationship.

Hedge Funds
Emerging & established managers seeking institutional-grade compliance
Private Equity Firms
Including fund-of-funds and credit managers
Family Offices
Transitioning to RIA registration or building compliance infrastructure
Institutional Allocators
Pension funds, endowments & fund-of-funds conducting ODD
Engagement Model

Flexible. Transparent. Aligned.

Three engagement structures to fit different needs and stages. All engagements are conflict-free — SCGRC does not accept referral fees or third-party compensation.

For Funds
OCCO Retainer
Retainer
Monthly & Annual Engagements

  • CCO of record designation
  • Full compliance program management
  • Annual review & regulatory filings
  • Ongoing monitoring & policy updates
  • Direct access to Daniel Dwyer
For Allocators
ODD Assessment
Per-Manager
or program basis

  • Governance & control environment review
  • Compliance infrastructure assessment
  • Operational integrity evaluation
  • Written ODD report & findings
  • Ongoing monitoring available

Ready to have a conversation?

Initial consultations are confidential and without obligation. Reach out to discuss your compliance needs, ODD requirements, or LGRC transformation.

ddwyer@stonycreekgrc.com
Email
ddwyer@stonycreekgrc.com
Phone
(860) 575-1792
Location
New York Metro Area
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