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Walkers

Tokenisation Series - How to Guide - Getting regulatory approval to issue RWA tokens from Jersey

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It is possible to issue RWA tokens using a Jersey company to act as the issuer. The Jersey regulator has published a guidance note on the tokenisation of RWAs. This guidance note sets out the applicable requirements and...more

K2 Integrity

Implementing FinCEN Final Rule Imposing Anti-Money Laundering Requirements On Investment Advisers

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On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...more

Perkins Coie

FDIC’s Proposed Changes to Custodial Deposit Accounts: Practical Implications for Fintechs and Their Banks

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The Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking (the Proposal) on September 17, 2024, that seeks to strengthen recordkeeping for bank deposits held by nonbank companies on behalf of...more

Seward & Kissel LLP

SEC Amends Regulation S-P to Require Data Breach Notifications and Additional Written Policies

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On May 16, 2024, the SEC amended Regulation S-P to impose new data privacy and security requirements on broker-dealers, registered investment advisers, investment companies (whether or not they are registered with the SEC),...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Morrison & Foerster LLP

The SEC Expands Focus on Cybersecurity Risk to Include Registered Advisers, Broker‑Dealers, and other Market Participants

Last month, the SEC took a big step toward strengthening the cybersecurity of financial systems by proposing regulations that, taken together, will require registered investments advisers, broker‑dealers, and all national...more

Paul Hastings LLP

SEC Proposes New Cybersecurity Rule and Amendments

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On March 15, 2023, the SEC issued proposed amendments and a proposed rule addressing cybersecurity. Specifically, the SEC proposed Rule 10, which addresses cybersecurity risks, and proposed to amend Regulation SCI and...more

King & Spalding

SEC Proposes RIA Outsourcing Rule

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On October 26, the SEC proposed a new Advisers Act rule (the “Proposed Rule”) that would establish specific obligations for Registered Investment Advisers with respect to outsourcing of “Covered Functions”, as that term is...more

Kilpatrick

Man the Cyber Forts! – SEC Proposes New Cybersecurity Regulations for RIAs and Funds

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With cybersecurity incidents increasing in frequency and notoriety, the Securities and Exchange Commission (the “SEC”) has set its sights on fortifying cybersecurity regulations across the entire financial industry, including...more

Jackson Lewis P.C.

SEC to Advisors and Funds – Adopt and Implement Cybersecurity Policies and Procedures

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On February 9, the Securities and Exchange Commission (“SEC”) voted to propose rule 206(4)-9 under the Advisers Act and 38a-2 under the Investment Company Act (collectively, “Proposed Rule”). In general, the Proposed Rule...more

Goodwin

SEC Adopts New Regulatory Framework For Registered Fund Derivative Investments

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On October 28, the Securities and Exchange Commission (the “SEC”) adopted Rule 18f-4 (the “Rule”) under the Investment Company Act of 1940 (the “1940 Act”) and amended related rules designed to provide a modernized,...more

Akin Gump Strauss Hauer & Feld LLP

NFA Issues Interpretive Notices for CPOs Regarding Internal Controls Systems and Cybersecurity

• The NFA has determined that registered CPOs must implement an internal controls system and highlighted best practices for such a framework. • In response to certain frequently asked questions, the NFA has also updated its...more

Akin Gump Strauss Hauer & Feld LLP

Five New Requirements Under New York DFS Cybersecurity Regulation Go Into Effect on September 1, 2018

On September 1, 2018, five new requirements included in the New York State Department of Financial Services’ (DFS) Cybersecurity Regulation go into effect – (1) audit trails, (2) application security, (3) data disposal...more

Jones Day

Board Practices in the Digital Age: Beyond Corporate Housekeeping

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The Background: Technology has transformed the way that directors receive and review information and communicate with each other and with management. The Issue: Although many modern board practices are more secure and...more

Dorsey & Whitney LLP

Minneapolis Sick and Safe Time Ordinance Compliance Guide

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On May 27, 2016, the Minneapolis City Council passed its long awaited Sick and Safe Time Ordinance, requiring most employers with employees working in the City of Minneapolis to provide paid sick/safe time to those employees...more

WilmerHale

Energy Sector Alert Series: Modern Compliance Programs in an Age of New Threats

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In this eight-week alert series, we are providing a broad look at current and emerging issues facing the energy sector. Attorneys from across the firm will discuss issues ranging from environmental disclosures and risk...more

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