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Compliance Libor

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
American Conference Institute (ACI)

U.K. Parliament Giving Whistleblower Protections a Fresh Review

Recent legislative developments in the United Kingdom, public remarks from the new director of the UK Serious Fraud Office (SFO), and recent parliamentary hearings on the Post Office Horizon scandal put a spotlight on...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - August 2023

Closed-End Fund Activism Update - Activist investors continue to take large positions in closed-end funds and engage in disruptive activity that may be harmful to long-term shareholders of retail closed-end funds. This...more

Nutter McClennen & Fish LLP

Nutter Bank Report: April 2023

FDIC and OCC Issue Guidance on Authorize Positive, Settle Negative Overdraft Fee Risks. The FDIC and the OCC each have issued supervisory guidance on consumer compliance risk exposure related to the assessment of overdraft...more

Morrison & Foerster LLP

SEC Division of Examinations’ 2023 Exam Priorities – A Continued Focus on Private Funds, Regulation Best Interest, ESG, and Crypto

On February 7, 2023, the Securities and Exchange Commission’s (SEC) Division of Examinations (EXAMs) announced its 2023 Examination Priorities (the “Priorities”), which highlight areas it expects to target in 2023...more

Goodwin

FinCEN Issues NPRM Regarding Access to Beneficial Ownership Information and Related Safeguards

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Regulatory Developments - FinCEN Issues NPRM Regarding Access to Beneficial Ownership Information and Related Safeguards - On December 15, FinCEN issued a Notice of Proposed Rulemaking (NPRM) that would implement...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2022

The Federal Reserve has adopted a final rule that provides benchmark replacement rates based on SOFR (Secured Overnight Financing Rate) for contracts governed by U.S. law that reference the overnight and one-, three-, six-,...more

Kaufman & Canoles

Credit Union Client Alert - Year-End Housekeeping for Credit Unions - Is Your “House” in Order?

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Credit unions should take the time to ensure your house is in order and fully compliant in every area before the year’s end. This will help prepare for new developments, rulings, guidance, settlement actions, and anything...more

White & Case LLP

Key Considerations for the 2022 Annual Reporting Season: Form 20-F and Other FPI-Specific Considerations

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This memorandum outlines key considerations from White & Case's Public Company Advisory Group for foreign private issuers ("FPIs") during the 2022 annual reporting season. This memo describes our key considerations for...more

White & Case LLP

Key Considerations for the 2022 Annual Reporting and Proxy Season Part I: Form 10-K Considerations

White & Case LLP on

This is Part I of a two-part series outlining key considerations from White & Case's Public Company Advisory Group for US public companies during the 2022 annual reporting and proxy season. Part I of this memo describes...more

Womble Bond Dickinson

Report: DOJ Launches Investigation into Alleged Energy Pricing Benchmark Fraud

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Investigators with the U.S. Department of Justice reportedly are investigating energy pricing benchmarks published by Platts, targeting suspected manipulation of deal prices provided by individual traders.  According to...more

Moore & Van Allen PLLC

UPDATED: Term SOFR vs BSBY vs Ameribor in the Loan Market

This is an update to a previous post. This update highlights the formal endorsement of Term SOFR by the ARRC, expands the discussion to include Ameribor and dives more deeply into the issues associated with Term SOFR swaps...more

Lowenstein Sandler LLP

Translating SEC Exam Priorities Into Compliance Action Items

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On March 3, the U.S. Securities and Exchange Commission announced its examination priorities for 2021, providing a much-anticipated glimpse into the Biden administration's overall priorities for white collar criminal...more

McDermott Will & Emery

LIBOR: Q1 2021 Snapshot

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On 5 March 2021, the Financial Conduct Authority (FCA) set out certain key dates for the cessation of all 35 London Inter-Bank Offered Rate (LIBOR) settings published by ICE Benchmark Administration. Whilst there has been...more

Fox Rothschild LLP

New SEC Division Undertakes 2021 Examination Priorities

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On December 17, 2020, SEC created the Division of Examinations by renaming the now defunct, Office of Compliance Inspections and Examinations, making it the SEC’s 6th Division joining Enforcement, Corporation Finance, Trading...more

Jones Day

FINRA Shares LIBOR Transition Preparation Practices of Broker-Dealers - FINRA has published helpful survey results on the...

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On August 5, 2020, FINRA published Regulatory Notice 20-26, summarizing the results of a survey FINRA conducted of a representative cross-section of member firms, including firms with significant trading volumes or positions...more

Dechert LLP

LIBOR: Time to put your foot down

Dechert LLP on

Andrew Bailey’s most recent speech on LIBOR transition (now in his new capacity as Governor of the Bank of England) likened the transition away from LIBOR to the game of cricket...more

Dechert LLP

SEC Publishes OCIE Risk Alert on LIBOR Transition Preparedness Examination Initiative

Dechert LLP on

The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations issued a National Exam Program Risk Alert on June 18, 2020 (Risk Alert), which introduces an examination initiative on the upcoming...more

A&O Shearman

SEC Identifies LIBOR Preparedness as an Examination Priority

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On June 18, 2020, the Securities Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) announced the details of an examination initiative specifically focused on LIBOR preparedness. OCIE has...more

Dorsey & Whitney LLP

SEC Exam Priorities For RIAs and ICs

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The Exam Priorities of the SEC’s Office of Inspections and Compliance or OCIE, announced on January 7, 2020 (the “Exam Priorities”), should be a key area of focus for every investment advisor and investment company. The Exam...more

Eversheds Sutherland (US) LLP

The heat is on - Regulators step up pressure to implement LIBOR transition plans

Regulators are increasing pressure on financial institutions to demonstrate that they are proactively addressing the transition away from LIBOR.  On December 23, 2019, the New York State Department of Financial Services...more

Robins Kaplan LLP

Financial Daily Dose 12.10.2019 | Top Story: Remembering Influential Former Fed Chair Paul Volcker

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Some remembrances upon the passing of influential former Fed Chair Paul Volcker, a force in American economic policy for nearly 60 years who led “the Federal Reserve’s brute-force campaign to subdue inflation in the late...more

Skadden, Arps, Slate, Meagher & Flom LLP

Form 20-F for Fiscal Year 2019: What Foreign Private Issuers Should Keep in Mind

There have been significant recent developments in U.S. Securities and Exchange Commission (SEC) regulation of foreign private issuers, (FPIs) including changes that impact the annual report on Form 20-F for fiscal year 2019....more

Morrison & Foerster LLP

Quarterly Cartel Catch-Up: Recent Developments in Criminal Antitrust for Busy Corporate Counsel - July 2019

Below, we summarize significant cartel enforcement developments from U.S. and other antitrust enforcers in recent months, including the significant change to longstanding policy by the Department of Justice (DOJ) Antitrust...more

The Volkov Law Group

Textbook Lessons Learned from the Société Générale and Legg Mason FCPA Enforcement Action (Part III of III)

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Sometimes it takes a large enforcement action to underscore basic and important anti-corruption compliance principles. The Société Générale enforcement action demonstrated two important principles – the dangers of a weak...more

The Volkov Law Group

Société Générale and Legg Mason Pay the Price for Bribery in Libya (Part II of III)

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Société Générale and Legg Mason carried out a massive bribery scheme to pay Gaddafi-era government officials in Libya in exchange for large investments by Libya government funds. In total, Société Générale and Legg Mason...more

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