Nasdaq has formally advanced its plan to extend U.S. equities trading to nearly 24 hours a day. On December 15, 2025, Nasdaq filed SR-NASDAQ-2025-106 with the U.S. Securities and Exchange Commission to introduce a new “Night...more
The Securities and Exchange Commission (“SEC”) has issued a no-action letter to the Depository Trust Company (“DTC”) in connection with the registered clearing agency’s pilot blockchain-based securities tokenization program....more
On December 11, 2025, the U.S. Securities and Exchange Commission (the “SEC”) issued no-action relief(the “DTC Letter”) to The Depository Trust Company (“DTC”) permitting for three years the operation of a pilot version (the...more
On December 11, 2025, the Depository Trust Co. (DTC) received what could prove to be a landmark no-action letter from the staff of the Securities and Exchange Commission (SEC) Division of Trading and Markets. In that...more
The Bank of England (BoE) has published its report on the results of its stress test of central counterparties (CCPs). The BoE conducts regular stress tests of UK CCPs to assess their financial resilience and identify...more
In this issue of our monthly Securities Enforcement Roundup, we highlight top securities enforcement developments from November 2025. In November 2025: The Division of Examinations of the Securities and Exchange Commission...more
On November 17, 2025, the Division of Examinations (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC”) published its annual 2026 Examination Priorities (the “Exam Priorities”). The Exam Priorities are...more
On November 17, 2025, the Securities and Exchange Commission’s (SEC) Division of Examination announced its fiscal year (FY) 2026 examination priorities. The most significant changes to the division’s priorities from FY 2025...more
At the recent 2025 U.S. Treasury Market Conference, Securities and Exchange Commission (“SEC”) Commissioner Mark T. Uyeda provided an update on the implementation of the Treasury Clearing Rules. In his remarks, Commissioner...more
The European Securities and Markets Authority (ESMA) has published its final reports under the revised European Market Infrastructure Regulation (EMIR 3) on: (i) draft regulatory technical standards (RTS) on the conditions...more
On September 30, 2025, the Securities and Exchange Commission (“SEC”) issued a press release, providing updates to market participants on the progress of implementing the rules on central clearing of certain secondary market...more
* [co-authors: Dan Carter, and Jason Carter] Companies that “go public” through nontraditional means—i.e., without an initial public offering (IPO) listed on a national securities exchange—face significant challenges to...more
On August 6, 2025, the Staff of the Division of Trading and Markets of the Securities and Exchange Commission (SEC) released an updated set of Frequently Asked Questions (FAQs) addressing the application of Rule 15c3-3a to...more
The Commodity Futures Trading Commission (CFTC) recently announced several new staff letters and public statements with material consequences for legal and business professionals in the derivatives markets. In this alert, we...more
On July 22, 2025, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight and Division of Clearing and Risk issued a no-action letter (CFTC Letter No. 25-23) granting targeted regulatory relief to the...more
The Bank of England (BoE) has published a consultation paper on a draft statement of policy (SoP) outlining its proposed approach to permissions, waivers and supervisory processes for central counterparties (CCPs), systemic...more
The European Securities and Markets Authority (ESMA) has published a consultation paper setting out draft regulatory technical standards (RTS) amending the RTS on the clearing thresholds (CTs) under the European Markets...more
The Committee on Payments and Market Infrastructures and the International Organization of Securities Commissions published a final report on examples of effective practices for streamlining variation margin in centrally...more
On December 20, 2024, the Securities and Exchange Commission (SEC) issued a final rule amending SEC rules 15c3-3 (the customer protection rule) and 15c3-1 (the net capital rule). The SEC also amended Form X-17A-5 Part II (the...more
On December 13, 2023, the Securities and Exchange Commission (the “SEC” or “Commission”) adopted rule amendments (the “Amendments”) under the Securities Exchange Act of 1934 that will, in effect, require direct participants...more
More than 50% increase in SEC cryptocurrency-related enforcement actions in 2023 over 2022. The Securities and Exchange Commission (SEC) continues to view cryptocurrency-related enforcement as a top priority, bringing 46...more
The Corporate Transparency Act mandates certain reporting requirements for beneficial ownership information for certain companies, with the goal of preventing the illicit use of anonymous shell companies for financial crimes....more
On December 13, 2023, the Securities and Exchange Commission (SEC) voted (4-1) to adopt new requirements under the Securities Exchange Act of 1934 (Exchange Act), which will restructure the clearance and settlement of...more
On November 20, 2023, the SEC filed a complaint in the United States District Court for the Northern District of California against Payward, Inc. and Payward Ventures, Inc. which, together, do business as Kraken. The...more
On October 16, 2023, the Division of Examinations (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC”) published its annual Examination Priorities for 2024 (the “Exam Priorities”). Consistent with the...more