Geoffrey Goldman

Geoffrey Goldman

Shearman & Sterling LLP

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SEC Proposes New Rule Requiring Investment Advisers to Adopt Business Continuity and Transition Plans Issues Guidance on Business...

A rule proposed by the US Securities and Exchange Commission under the Investment Advisers Act of 1940 would require SEC-registered investment advisers to adopt and implement written business continuity and transition plans...more

7/8/2016 - Business Continuity Plans Investment Adviser Proposed Regulation SEC

Brexit for Fund Managers: Time for Cool Heads

The UK electorate voted to leave the European Union (EU) in the “Brexit” referendum held on 23 June 2016. This note looks at the practical impact of a Brexit for fund managers, including possible solutions in the event that...more

7/6/2016 - AIFMD EEA EU MiFID II UCITS UK UK Brexit

SEC Increases Qualified Client Net Worth Threshold

Every five years, the US Securities and Exchange Commission is required to adjust for inflation the agency’s dollar-based qualification tests for when an SEC-registered investment adviser can receive compensation based on...more

6/28/2016 - High Net-Worth Investment Advisers Act of 1940 Qualified Purchaser Registered Investment Advisors SEC

Financial Regulatory Developments Focus - June 2016 #2

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

6/23/2016 - Annual Reports Bank Holding Company Capital Markets Union Capital Requirements Cybersecurity Dodd-Frank EU EU Market Abuse Regulation (EU MAR) Long-Term Investment Funds No-Action Relief UK

FinCEN Issues Final Beneficial Owner Identification Rules

In May 2016, the U.S. Treasury Department’s Financial Crimes Enforcement Network issued final rules regarding beneficial owner identification obligations for legal entity customers (the “Rule”). Under the Rule, covered...more

6/15/2016 - Anti-Money Laundering Beneficial Owner Customer Identification Program (CIP) Final Rules FinCEN

Financial Regulatory Developments Focus - June 2016

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

6/9/2016 - EU Benchmark Regulation Form 10-K G-SII MiFID II Payday Loans Position Limits Prudential Standards Shadow Banking Stress Tests

CFTC Adopts Final Rules Regarding the Cross-Border Application of Its Swap Margin Requirements

On May 24, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) adopted a final rule defining the cross border application of its margin requirements for uncleared swaps. The final rule covers all swap dealers and...more

6/9/2016 - CFTC Cross-Border Final Rules Margin Requirements Swaps

SEC To Increase Qualified Client Net Worth Threshold

Every five years, the U.S. Securities and Exchange Commission is required to adjust for inflation the agency’s dollar-based qualification tests for when an SEC-registered investment adviser can receive compensation based on...more

6/6/2016 - High Net-Worth Investment Adviser SEC

Financial Regulatory Developments Focus - May 2016 #3

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

6/1/2016 - Basel III Beneficial Owner Capital Requirements Cross-Border Transactions Customer Due Diligence (CDD) EU Leverage Ratio Leveraged Lending Margin Requirements Recordkeeping Requirements Regulation Technical Standards (RTS) UCITS UK

Financial Regulatory Developments Focus - May 2016 #2

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

5/18/2016 - Benchmarking Distributed Ledger Insider Trading Liquidity Coverage Ratio Regulatory Standards Senior Managers Yates Memorandum

Financial Regulatory Developments Focus - May 2016

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

5/6/2016 - AML-CTF Annuities Asset Management Capital Markets Union Capital Requirements Cross-Border Transactions EU Incentive Compensation Leverage Ratio MiFID II SIFIs UK

US Financial Stability Oversight Council Focuses on Asset Management Products and Activities

On April 18, 2016, the US Financial Stability Oversight Council issued an update on its multi-year review of potential financial stability risks in the asset management industry. This note highlights takeaways from that...more

4/27/2016 - Asset Management Capital Markets Union EU FSOC Popular Risk Assessment UK

Financial Regulatory Developments Focus - April 2016 #2

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

4/15/2016 - Anti-Inversion Regulations EU FBOs Fiduciary Duty Financial Adviser FinTech FSOC Global Systemically Important Financial Institutions (GSIFI) Leverage Ratio MetLife Terrorism Funding UK

Financial Regulatory Developments Focus - April 2016

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

4/11/2016 - Asset Management Block Chain CFTC Corporate Governance Cybersecurity Economic Sanctions EU Federal Reserve Industry Consolidation Maxwellisation Municipal Securities Issuers Natural Gas Remuneration Stress Tests UK

CFTC’s Publication of Largest Whistleblower Award Follows Increased Focus on Whistleblowing Initiatives

On April 4, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) announced the issuance of a whistleblower award of more than $10 million for original information that it said led to a major enforcement action over...more

4/6/2016 - CFTC Commodities Exchange Act Dodd-Frank Whistleblower Awards

Financial Regulatory Developments Focus - March 2016 #4

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

4/1/2016 - Capital Markets Union EU Eurozone GAAP Interchange Fees MiFID II Mortgage Credit Directive (MCD) Prudential Standards Ring-Fencing SIFIs SMEs UCITS V UK UK Payment Systems Regulator

Financial Regulatory Developments Focus - March 2016 #3

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

3/25/2016 - BRRD Central Counterparties Cuba Deposit Insurance Derivatives Clearing Organizations Dodd-Frank EU Foreign Exchanges Goldman Sachs Insider Trading Payment Systems Sanctions UK Volcker Rule

Financial Regulatory Developments Focus - March 2016 #2

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

3/18/2016 - Basel Committee Credit Default Swaps EU FDIC Federal Savings Associations International Banks Libor Market Abuse Regulatory Agenda Ring-Fencing SEC Senior Managers Transfer Pricing UK Volcker Rule

Update on Third Country Equivalence Under EMIR

The European Commission has adopted an “equivalence” decision on the derivatives regulatory regimes for derivatives clearing organisations in the United States. This follows the decisions adopted in November 2015 for Canada,...more

3/17/2016 - CCPs Derivatives EMIR EU European Securities and Markets Authority (ESMA)

Financial Regulatory Developments Focus - March 2016

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

3/3/2016 - Bank Secrecy Act Banking Examinations Cooperation Enforcement Actions EU Money Transfer MREL Payment Systems Stress Tests UK Volcker Rule

Financial Regulatory Developments Focus - February 2016 #3

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

2/25/2016 - Bailout Banking Examinations Consumer Credit Act Dodd-Frank EU Federal Reserve Financial Crisis G-SII International Remittance Transfers Security-Based Swaps

Financial Regulatory Developments Focus - February 2016 #2

Bank Prudential Regulation & Regulatory Capital US Federal Deposit Insurance Corporation Issues Proposed Rule to Facilitate Access to Deposits in Large Bank Failures On February 17, 2016, the US Federal Deposit Insurance...more

2/19/2016 - Anti-Terrorism Financing Central Counterparties EU Federal Reserve Liquidation Payment Systems Regulation C Regulation Technical Standards (RTS) Senior Managers Insurers Regime (SMIR) Stress Tests UK

EU-US Agreement on Regulation of Central Counterparties

On 10 February 2016, the European Commission and the CFTC announced a common approach regarding supervision of central counterparties operating in the US and EU, paving the way for cross-border equivalence and recognition...more

2/17/2016 - Central Counterparties CFTC EMIR EU European Commission Supervision

Financial Regulatory Developments Focus - February 2016

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

2/8/2016 - Anti-Money Laundering Capital Requirements Cybersecurity Deposit Insurance Dodd-Frank FDIC Market Abuse Memorandum of Understanding Mexico Prudential Standards Rating Agencies Regulation Technical Standards (RTS) SEFs South Africa

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