Hong Kong has seen cryptocurrencies grow in popularity, highlighting the need for appropriate licensing regimes (implemented in the form of virtual asset service providers (VASPs)), bolstered by active enforcement actions. ...more
Key Takeaways - The COVID-19 coronavirus outbreak has undoubtedly increased firms’ exposure to market abuse risks in a number of ways: Due to the rapidly changing consequences of restrictions caused by COVID-19 for...more
Under the Senior Managers and Certification Regime (“SMCR”), firms are required to identify and report to the FCA any instances of disciplinary action taken in relation to conduct that would amount to a breach of one of the...more
On July 9, 2019, the United Kingdom’s Financial Conduct Authority (FCA) published its latest Enforcement annual performance report for the year 2018/19. This follows the publication of its final FCA Mission: Approach to...more
On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more
Just days after Facebook announced its shift to more private communications, the company’s chief product officer (and longtime Zuck inner-circler) Chris Cox and WhatsApp head Chris Daniels are both heading out the door,...more
FCA Consults on Rules for Post-Brexit Temporary Permissions Regime for Incoming EEA Firms and Funds - The UK government is proposing to implement a “temporary permissions regime” to cover “inbound” European Economic Area...more
During the prior two weeks, three financial authorities in the United Kingdom as well as the Hong Kong Securities and Futures Commission issued reports assessing distributed ledger technology and risks associated with the...more
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
This newsletter provides a snapshot of the principal U.S. and selected international governance and securities law developments during the fourth quarter of 2017 that may be of interest to Latin American corporations and...more
Since January 2017, more than $2 billion has been raised through the rapidly growing market for so-called “token sales” or “initial coin offerings” (ICOs). The U.S. Securities and Exchange Commission (SEC) announced on July...more
SEC Begins Proactively Suggesting Some Promoters Halt ICOs; the UK Financial Conduct Authority Joins Worldwide Regulators Saying that Digital Tokens Issued as Part of ICOs May Be Securities: Following the release of the...more
Key Points - - All managers of SFC authorised funds (including overseas managers of SFC authorised funds) are required to enhance internal liquidity risk management processes and procedures in order to implement...more
The Foreign Corrupt Practices Act was a key focus this week. The DOJ announced a new one year Pilot Program which holds the promise of a significant reduction in penalties if the firm self-reports and takes a series of steps....more
1st Day of Christmas – UCITS V* - The UCITS V Directive (UCITS V) introduces specific provisions on: - (i) eligibility, liability and delegation of depositaries; - (ii) remuneration policies; and ...more