William Sweet, Jr.

William Sweet, Jr.

Skadden, Arps, Slate, Meagher & Flom LLP

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Latest Publications


"Insights Conversations: Update on Shareholder Activism in the US Banking Industry"

Two years ago, the U.S. banking industry was a rare exception to the trend of increased shareholder activism that was prevalent across industries. At the time, Skadden partners Brian Christiansen, David Ingles, Sven Mickisch...more

10/1/2015 - Acquisitions Banking Sector Board of Directors Corporate Management Investors Mergers Shareholder Activism

"OFAC and BIS Further Ease Cuba Restrictions"

On September 21, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) amended their respective Cuba regulations to...more

9/30/2015 - Airlines BIS Cuba Cuban Assets Control Regulations (CACR) Export Administration Regulations Export Controls Financial Institutions Financial Transactions Information Technology Internet Service Providers Licenses OFAC Physical Presence Test Sanctions Telecommunications U.S. Commerce Department Vessels

"A Long Time Coming: FinCEN Proposes AML Program and SAR Requirements for Investment Advisers"

On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) that would impose certain anti-money laundering (“AML”) requirements on...more

9/11/2015 - Anti-Money Laundering Bank Secrecy Act BSA/AML Currency Transaction Reports (CTR) FinCEN Investment Adviser Know Your Customers NPRM OCIE SEC Suspicious Activity Reports U.S. Treasury

"President Obama Announces New Cybersecurity Sanctions Regime"

On April 1, 2015, President Barack Obama issued an executive order (the Order) authorizing sanctions against foreign individuals or entities found to be responsible for certain malicious cyberattacks. Under the Order, the...more

4/9/2015 - Barack Obama Blocked Person CFIUS Cyber Attacks Cybersecurity Executive Orders OFAC Sanctions SDN List

"New Reporting Requirements on the Horizon for US Financial Services Providers Doing Business With Non-US Persons"

Following closely on the heels of the reinstated reporting requirements for inbound and outbound direct investment involving U.S. entities, the U.S. Department of Commerce’s Bureau of Economic Analysis (BEA) has announced...more

3/3/2015 - Banking Sector Bureau of Economic Analysis Financial Institutions Foreign Direct Investment Foreign Nationals Reporting Requirements U.S. Commerce Department

"New Provisions Require Structural Change for Foreign Banking Organizations"

The Enhanced Prudential Standards (Regulation YY) of the Board of Governors of the Federal Reserve System represent a significant shift in the U.S. regulation of foreign banking organizations (FBOs). In general, Regulation...more

2/6/2015 - Bank Holding Company Banking Sector Banks Dodd-Frank Federal Reserve Foreign Banks Prudential Standards Regulation YY

"MiFID 2: Reforming the Regulation of EU Securities and Derivatives Markets"

The European Union has begun a wide-ranging and radical reform of its securities and derivatives markets through MiFID 2, which is scheduled to be implemented across the EU by January 3, 2017. Implementation is dependent on a...more

1/28/2015 - Derivatives EU Financial Regulatory Reform MiFID Securities

"Lawmakers and Regulators Continue Focus on Strategies for Resolving SIFIs"

The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 contains two sets of provisions for managing the insolvency of financial institutions. First, the legislation creates an Orderly Liquidation Authority...more

1/28/2015 - Banking Sector Bankruptcy Code Banks Counterparties Debt Restructuring Dodd-Frank FBOs FDIC Federal Reserve Financial Institutions Insolvency ISDA Living Will Orderly Liquidation Authority SIFIs

"OFAC and BIS Implement Changes in Cuba Policy"

Since the 1960s, the United States has maintained an embargo on Cuba that in many respects is the most comprehensive set of economic and trade restrictions on any country. On January 16, 2015, amendments to regulations issued...more

1/21/2015 - Amended Regulation Banking Sector BIS Cuba Embargo Executive Orders Exports Imports Obama Administration OFAC Sanctions Telecommunications Trade Relations Travel Permits

"European Central Bank Publishes Final List of 'Significant Supervised Entities' in Preparation for Banking Union"

On 4 September 2014, the EU’s European Central Bank (ECB) published its final list of significant supervised entities and less significant institutions for the purposes of the Eurozone’s single supervisory mechanism (SSM),...more

9/15/2014 - EU European Central Bank Foreign Banks Single Supervisory Mechanism

"An Update on Economic Sanctions Related to Events in Ukraine"

On April 25, 2014, following a meeting of the G7 in which member countries broadly agreed to take further action against Russia in response to political violence and unrest in Ukraine, U.S. officials imposed sanctions against...more

5/7/2014 - EU OFAC Russia Sanctions Ukraine

"US Government Announces Ban on High-Technology Exports to Russia and Crimea"

On April 28, 2014, as part of its evolving response to the situation in Ukraine, the White House announced new restrictions on exports of “high-technology” items and services to Russia and Crimea. The announcement also...more

5/2/2014 - Exports Russia Sanctions Technology Ukraine

"EU Banking Union: Political Agreement Reached on Single Resolution Mechanism"

On March 20, 2014, the European Parliament announced that it had reached political agreement with the European Council on the regulation implementing a single resolution mechanism (SRM), which is an essential element of the...more

4/10/2014 - Banking Sector Banks EU Financial Regulatory Reform Foreign Banks

"US Government Halts Licensing for Key Exports to Russia in Response to Events in Ukraine"

In a further sign of the broadening of U.S. restrictions relating to Russia because of the situation in Ukraine, the United States has taken steps to limit trade with Russia in U.S.-origin goods and services that are...more

4/4/2014 - DDTC Exports Licenses Ukraine

"An Update on Economic Sanctions Related to Events in Ukraine"

Last week the United States and European Union continued to ramp up economic sanctions related to events in Ukraine and Russia. Because the most recent round of sanctions is likely to have a much broader reach, entities must...more

3/27/2014 - Foreign Policy Russia Sanctions Ukraine

"An Update on Economic Sanctions Related to Events in Ukraine"

In the wake of Sunday’s referendum in Crimea to secede from Ukraine, the United States and the European Union imposed economic sanctions on several high-level public officials in Ukraine and Russia. Please see our alert dated...more

3/18/2014 - EU Russia Sanctions Ukraine

"Economic Sanctions Related to Events in Ukraine"

With the events unfolding in Ukraine, many entities are assessing the potential impact on their international activities of U.S. and European sanctions. This alert highlights some key aspects of the U.S. and EU sanction...more

3/10/2014 - Barack Obama EU Executive Orders Sanctions Ukraine

"UK Banking Regulators and Foreign Banks: A Vision of Future Supervision"

The U.K.’s banking regulator, the Prudential Regulation Authority (PRA) recently published a consultation paper on its approach to supervising international banks (the Draft Supervisory Approach). ...more

3/7/2014 - Banks Foreign Banks Prudential Regulation Authority UK

"Outsourcing by Financial Services Companies: Impact of the OCC and FRB Guidelines"

Outsourcing has become a critical component of financial institutions’ management of their business operations and control of their costs. In addition, institutions are outsourcing increasingly complex and sensitive banking...more

2/10/2014 - Employer Liability Issues Federal Reserve FRB OCC Outsourcing Third-Party Risk

"Bank Regulators Eye Leveraged Lending"

Historically low interest rates in the United States have helped to fuel tremendous growth in leveraged loans. Leveraged loan volume in 2013 surpassed record levels set just prior to the global financial crisis, as banks and...more

1/30/2014 - Banks FDIC Federal Reserve Financial Regulatory Reform Leveraged Loans OCC Underwriting

The Volcker Rule: A First Look at Key Changes

On December 10, 2013, five U.S. financial regulators (the Agencies) adopted a final rule implementing the Volcker Rule. The text of the final rule and its accompanying preamble are available here. The Volcker Rule was created...more

12/12/2013 - Asset-Backed Securities Banks CEOs Dodd-Frank Exemptions Hedge Funds Market Making Private Equity Reporting Requirements Sovereign Debt Volcker Rule

"US Financial Regulators Issue Final Volcker Rule"

Yesterday, U.S. financial regulators issued the final Volcker Rule. The Volcker Rule implements provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act that prohibit banking organizations from engaging in...more

12/11/2013 - Dodd-Frank Financial Regulatory Reform Volcker Rule

"European Union Banking Reform Update"

By the end of this year, the European Commission will present its legislative proposals for EU banking structural reform. Once the proposals are implemented, EU banks will have to separate their “investment” business from...more

11/22/2013 - Banking Sector Capital Requirements EU European Commission Segregation Requirements UK Volcker Rule

"Shareholder Activism in the US Banking Industry"

Although the 2012 and 2013 proxy seasons saw increased (and highly publicized) shareholder activism across a range of industries, that trend has not yet made its way to the U.S. banking industry. Over the last two proxy...more

11/12/2013 - Executive Compensation ISS Say-on-Pay Shareholder Activism Shareholder Litigation Shareholders

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