News & Analysis as of

Implementation Day

Treasury Department Urges Principles-Based Regulation of Money Managers; Delay of Implementation of Liquidity Risk Management and...

by Morrison & Foerster LLP on

The U.S. Department of the Treasury’s report on asset management and insurance recommends, among other things, a delay in implementation of the SEC’s liquidity risk management rule and the Department of Labor’s fiduciary...more

BREAKING NEWS — ERISA: DOL Publishes TODAY Proposed Rule to Delay Implementation of New ERISA Claims Regulations?

You already know that since December 2016 the United States Department of Labor (DOL) has been reworking regulations governing disability plan administration. ...more

NYSE Seeks to Delay Dividend Notification Change

by Goodwin on

The New York Stock Exchange (“NYSE”) is seeking to delay the implementation of its recently-adopted dividend notification requirements until no later than February 1, 2018....more

Possible Further Delay of ERISA Fiduciary Rule

On August 9, 2017, the Department of Labor (DOL) and Secretary of Labor, Alexander Acosta, submitted a proposal to the Office of Management and Budget (OMB) to further delay the applicability date of certain parts of the...more

Department of Labor Seeks Delay of Fiduciary Rule Implementation Until July 2019

by Hinshaw & Culbertson LLP on

The U.S. Department of Labor has moved to delay implementation of three exemptions of the “fiduciary rule” until July 2019. The regulation, which partially went into effect earlier this year, requires financial advisers to...more

OSHA Proposes Delay for New Injury Reporting Requirements

Late last month, the Federal Occupational Safety and Health Administration (OSHA) announced a proposed delay for implementation of its new injury and illness reporting requirements until December 1. The rule originally was...more

Implementation of the DOL Fiduciary Rule, a Cheat Sheet

Implementation Date - The first phase of the DOL’s fiduciary rule is scheduled to be implemented on June 9, 2017. Please see full Cheat Sheet below for more information. ...more

Structured Thoughts: News for the financial services community, Volume 8, Issue 5

Implementing the DOL Fiduciary Rule - Background - On June 9, 2017, key provisions of the fiduciary rule adopted by the Department of Labor (“DOL”) will become applicable for most broker-dealers, as well as many...more

Living with the DOL Fiduciary Rule: Be Prepared for the June 9 Implementation Date

by Morrison & Foerster LLP on

The first phase of the Department of Labor’s (“DOL”) new fiduciary rule (“Fiduciary Rule”) is scheduled to be implemented on June 9, 2017. The Fiduciary Rule greatly expands the categories of persons who are deemed...more

Jones Act Battles, Administrative Appointees on the Move, and Combative Hearings Shape the Landscape

by Cozen O'Connor on

This edition of the Cozen O’Connor Maritime and Infrastructure Federal Update discusses (i) the Jones Act conflict developing before Customs and Border Protection with respect to the use of foreign flag vessels to perform...more

Implementation of the European Union Directive on Antitrust Damages Actions into French Law

by McDermott Will & Emery on

On 10 March 2017, France finally implemented into French law the EU Directive 2014/104 of 26 November 2014 on antitrust damages actions. The implementation provisions faithfully transpose the Directive, but some concepts...more

DOL Provides Temporary Enforcement Relief on Fiduciary Rule

by Foley Hoag LLP on

The U.S. Department of Labor (“DOL”) issued a Field Assistance Bulletin (FAB 2017-01) on Friday, March 10, 2017 to address near-term compliance concerns relating to a proposed 60-day delay of the Fiduciary Rule. As previously...more

OFAC Provides Prospective Guidance on Potential “Snap-Back” of Iran Sanctions

by K&L Gates LLP on

On December 15, 2016, the Office of Foreign Assets Control (“OFAC”) in the Department of the Treasury amended its Frequently Asked Questions guidance document (“FAQs”) regarding the Joint Comprehensive Plan of Action...more

OFAC Provides Further Guidance On Iranian Sanctions

by Reed Smith on

This month the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) updated its ‘Frequently Asked Questions Relating to the Lifting of Certain U.S. Sanctions Under the Joint Comprehensive Plan of Action (JCPOA)...more

CFPB Finalizes Sweeping Prepaid Account Rule

by Morrison & Foerster LLP on

On October 5, 2016, the Consumer Financial Protection Bureau (“CFPB”) issued its long-awaited final rule to further regulate prepaid card products, or “prepaid accounts” (the “Final Rule” or “Rule”). The Final Rule follows...more

From Implementation to Takeoff: Nine Months Later, OFAC Issues Licenses to Boeing and Airbus for Commercial Aircraft Deals With...

The beginning of the year brought the arrival of “Implementation Day” under the Joint Comprehensive Plan of Action (JCPOA) and its potential for business opportunities in Iran that had been shut off for decades (See Jan. 22,...more

International Arbitration Newsletter - July 2016

by Latham & Watkins LLP on

Privy Council clarifies the nature of arbitration clauses, but uncertainties about the clauses’ effect still remain. “Non-exclusive” arbitration clauses provide that disputes “may” be referred to arbitration (rather than...more

US Issues Additional Guidance Regarding Iran Sanctions Relief

by White & Case LLP on

On June 8, 2016, the US further clarified the scope of the sanctions relief provided to Iran as of January 16, 2016 (known as "Implementation Day") under the Joint Comprehensive Plan of Action (JCPOA). The Department of the...more

European Union and United Kingdom Sanctions Update: May 2016

by K&L Gates LLP on

Below is a summary of developments since our previous update in March relating to European Union (“EU”) sanctions on Iran, North Korea and other jurisdictions as well as highlights of recent changes with respect to the...more

Investment in Iran After Implementation Day

by WilmerHale on

January 16, 2016, marked the Implementation Day that recognised the certification by the International Atomic Energy Agency that Iran had met its obligations under the July 2015 Joint Comprehensive Plan of Action (JCPOA), a...more

Implementation Day Arrives For Iran Agreement

by King & Spalding on

On January 16, the International Atomic Energy Agency announced that Iran has fully implemented its nuclear-related commitments described under the Joint Comprehensive Plan of Action (JCPOA) bringing about Implementation Day...more

Iran Sanctions Eased, But Restrictions Remain

by Hodgson Russ LLP on

Canadian companies with U.S. operations must keep alert to developments in U.S. sanctions laws. Such sanctions apply to any entity organized under the laws of a U.S. jurisdiction (regardless of foreign ownership of such...more

Implementation of New UK PSC Regime

by Morgan Lewis on

UK companies will be obliged to take steps to identify and maintain a public register of persons with significant control, and such persons must supply such companies with information for inclusion on the register or face...more

Iran Secondary Sanctions Relaxation: Effect on Shipping and Related Activities

by Morgan Lewis on

Shipping companies should be mindful of restrictions that still apply. The relaxation of Iran sanctions that the United States implemented on January 16, 2016—“Implementation Day” for the Joint Comprehensive Plan of...more

Tokyo Dispute Resolution and Crisis Management Newsletter - February 2016

by King & Spalding on

Implementation Day Arrives: Sanctions on Iran are Lifted - Status update on the effect to US and EU Sanctions - Implementation Day – the day the International Atomic Energy Agency (“IAEA”) announced that Iran had...more

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