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SEC Puts LIBOR Transition Testing in Focus

In anticipation of LIBOR discontinuation, the SEC will begin examining transition progress. Nearly a year after the US Securities and Exchange Commission’s (SEC’s) release of a Staff Statement on LIBOR Transition, the...more

Caring for the CARES Act: The New Oversight and Investigations Landscape for COVID-19 Relief Programs

Economic aid legislation will likely result in increased scrutiny of certain industries, similar to investigations that followed relief efforts in the 2008 financial crisis. Key Points: ..The CARES Act creates multiple...more

A CFTC Helping Hand: DSIO Offers to Review Digital Asset Products

Product innovation (including in pooled investment vehicles) is encouraged, but innovation must be consistent with the law. The US Commodity Futures Trading Commission’s (CFTC’s) Division of Swap Dealer and Intermediary...more

The CFTC Takes New Steps to Promote Innovation and ‘Explore the Unwritten Future’

The US derivatives regulator continues to foster FinTech adoption and leadership in US markets. The US Commodity Futures Trading Commission (CFTC) has affirmed its commitment to engaging the fast-moving financial...more

Financial Firms Beware: Dangers Lurk in the Cloud

US regulators are calling attention to financial firms’ obligations to protect against evolving cybersecurity threats. On October 2, 2019, the Financial Industry Regulatory Authority (FINRA) issued an information notice to...more

The SEC Continues Its Enforcement Streak Against Unregistered Token Offerings

As the agency pursues and prevents offerings of tokens it deems unregistered securities, further issues emerge. The recent wave of US Securities and Exchange Commission (SEC) enforcement actions relating to initial coin...more

LIBOR Discontinuation and Transition - What Investment Managers Should Know

The global shift away from LIBOR presents a complex, time-sensitive, multifaceted set of challenges and tasks for the investment management industry. In a statement published on July 12, 2019, the US Securities and...more

SEC Ends 2018 Signaling Its Approach to Regulating the Cryptocurrency Markets

Recent actions reinforce the SEC’s commitment to applying traditional securities markets regulation in the cryptocurrency markets. The US Securities and Exchange Commission (SEC, or the Commission) recently issued a public...more

SEC Charges “ICO Superstore” as Unregistered Broker-Dealer

The settled order is the first SEC action charging a seller of digital tokens as an unregistered broker-dealer. On September 11, 2018, the U.S. Securities and Exchange Commission (SEC) announced a settled order instituting...more

Global Developments on Best Execution

Best execution is currently a hot topic for global regulators and the past year has seen notable regulatory focus in this area. Amid this development, firms are recommended to review their global best execution compliance...more

Are Your Employees Trading Bitcoin? Addressing Cryptocurrencies in Compliance Policies

How should broker-dealers, investment advisers, and other registered firms in the US, UK, and Hong Kong address cryptocurrencies in their compliance programs? Originally published on bloombergbna.com on April 16,...more

CFTC Proposes Interpretation of “Actual Delivery” for Virtual Currencies

The proposed interpretation would further clarify the CFTC’s jurisdiction over virtual currency platforms that facilitate retail commodity transactions. On December 15, 2017, the US Commodity Futures Trading Commission...more

DOJ Expands and Codifies Policy Incentivizing Corporations to Voluntarily Self-Disclose FCPA Violations

The revised FCPA Corporate Enforcement Policy signals DOJ’s emphasis on corporate voluntary self-disclosure, rewarding cooperating companies with a presumption in favor of declination and reductions in penalties. ...more

Deputy Attorney General Announces Comprehensive Review of DOJ Corporate Enforcement Policies

Key Points: - DOJ is reviewing and reevaluating numerous corporate enforcement policies, including the “Yates Memo,” the FCPA Pilot Program, and policies on corporate monitors. - Policies will be codified in official...more

Divided Second Circuit Broadens Personal Benefit Test for Insider Trading Liability

The court’s Martoma decision reinvigorates the US government’s ability to prosecute insider trading cases. Key Points: - The majority opinion overrules recent case law requiring that an insider have a meaningfully close...more

What Do the SEC’s Recent Bitcoin Disapproval Orders Really Mean for Investors?

Regulators responded to a narrow question about trading bitcoin-based securities, with orders that should not limit innovation in bitcoin technologies. On March 10, 2017, the US Securities and Exchange Commission (SEC)...more

CFTC Releases New Enforcement Cooperation Guidelines

The agency’s updated advisory for companies and first-ever guidance for individuals shed additional light on its approach for recognizing cooperation. On January 19, 2017, the Division of Enforcement (Division) of the...more

CFTC Proposes New Enforcement Authority and Other Amendments in Its Whistleblower Program

Mirroring existing SEC authority, the CFTC’s proposal would allow it to impose sanctions for retaliation against whistleblowers. On August 30, 2016, the US Commodity Futures Trading Commission (CFTC) published proposed...more

CFTC Brings Significant Enforcement Action Against Online Cryptocurrency Exchange

The action reflects the CFTC’s expanded jurisdiction and provides further clarity on what constitutes “actual delivery” in cryptocurrency trading. On June 2, 2016, the US Commodity Futures Trading Commission (CFTC)...more

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