On May 2, 2013, the SEC filed an order instituting settled administrative proceedings against the trustees (“Trustees”) and certain service providers of two “turnkey” open-end series investment companies, Northern Lights Fund...more
The Securities and Exchange Commission today charged the trustees of two “turnkey” mutual fund trusts with causing untrue or misleading disclosures about their review of the funds’ advisory contracts. The Commission also...more
On 26 December 2012 (the “Effective Date”), Bank Indonesia (“BI”) published Regulation No. 14/24/PBI/2012 (“Regulation 14”) which contains a revised version of the single presence policy applicable to...more
In last month’s newsletter, we discussed how developments in 2012 had considerably tightened sanctions against Iran, including through the first-ever application of sanctions to separately incorporated subsidiaries of U.S....more
The federal Centers for Medicare and Medicaid Services (CMS) published a final regulation to further implement section 6113 of the federal health reform law, the Patient Protection and Affordable Care Act. The March 19, 2013,...more
Multinational companies in the automotive supply sector could face heightened enforcement risks under new sanctions on Iran. Effective March 8, 2013, U.S. parent companies will become liable for Iran-related sanctions...more
On August 10, 2012, the United States delivered its latest economic blow to Iran by enacting the Iran Threat Reduction and Syria Human Rights Act of 2012. U.S. companies have long been forbidden from engaging in most...more
The end of the year was very tough for global banks. For months significant enforcement actions were expected in the ongoing LIBOR manipulation probe and anti-money laundering and sanctions violations probes....more
Originally published in Thomson Reuters - Securities Regulation Law Journal - Winter 2012.
Faced with the possibility of litigating against the Securities and Exchange Commission (SEC) or the Financial Industry...more
The new SEC bounty-hunter regime, the explosion in whistleblower claims, and the increasing severity and complexity of those claims raises the specter of government investigations and criminal sanctions....more
The Securities and Exchange Commission’s Annual Report on the Dodd-Frank Whistleblower Program, released November 2012, provides the first complete year of data on the activities of the Office of the Whistleblower (“OWB”)...more
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