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Morrison & Foerster LLP

CFTC Advisory Outlines Materiality Criteria for Enforcement Referrals

On April 17, 2025, three operating divisions (the “Operating Divisions”) of the U.S. Commodity Futures Trading Commission (“CFTC”) and the Division of Enforcement (“DOE”) provided guidance in CFTC Letter 25-13 (the...more

BakerHostetler

CFTC Provides Clarifying Guidance on Material Violations Regarding Self-Reporting, Cooperation, and Remediation System

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As we previously reported, in February, the CFTC’s DOE issued an enforcement advisory (the DOE Advisory) to provide guidance to market participants on how the DOE will evaluate a company’s or an individual’s conduct in the...more

Ballard Spahr LLP

OCC, FDIC eliminating ‘reputational risk’ from supervision, examinations

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The OCC has removed “reputational risk” from its handbooks and guidance and the FDIC is moving to do the same. ...more

Husch Blackwell LLP

CFTC Releases Criteria for Operating Divisions to Refer Violations to Enforcement Division

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On April 17, 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division (MPD), the Division of Clearing and Risk (DCR), and the Division of Market Oversight (DMO)—collectively the Operating...more

Hogan Lovells

Staying antitrust compliant: New BAFA guidance on sector initiatives in supply chain due diligence

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Supply chain due diligence has firmly taken root in the global regulatory landscape, setting clear compliance expectations on how companies should identify, assess, and address human rights and environmental risks across...more

Davis Wright Tremaine LLP

CFTC Divisions Issue Staff Advisory on Referrals to Division of Enforcement

On April 17, 2025, the Market Participants Division, the Division of Clearing and Risk, and the Division of Market Oversight (collectively, the "Operating Divisions") of the CFTC, along with the Division of Enforcement...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Issues Advisory on Referrals to the Division of Enforcement

On April 17, 2025, three operating divisions of the Commodity Futures Trading Commission (CFTC) jointly issued an advisory to provide guidance on the materiality or other criteria they will use in deciding whether to make a...more

BCLP

Are You Ready for Martyn’s Law?

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The Terrorism (Protection of Premises) Act received Royal Assent on 3 April 2025 and is expected to be implemented within the next 24 months. There will be no legal requirement to comply until the legislation comes into...more

DLA Piper

White House Releases Guidance for AI Acquisition and Use in Government

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New guidance emphasizes risk-based governance, requires “impact assessments” - On April 7, 2025, the White House Office of Management and Budget (OMB) released two memoranda, outlining its latest guidance for federal...more

Ropes & Gray LLP

White House Issues Guidance on Use and Procurement of Artificial Intelligence Technology

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On April 3, 2025, the White House Office of Management and Budget (“OMB”) issued two memoranda, Accelerating Federal Use of AI through Innovation, Governance, and Public Trust (M-25-21) and Driving Efficient Acquisition of...more

A&O Shearman

Pensions: What’s new this week? April 14, 2025

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Welcome to your weekly update from the A&O Shearman Pensions team, covering all the latest legal and regulatory developments in the world of workplace pensions. TPR Climate change report - The Pensions Regulator (TPR) has...more

Morgan Lewis

Key Messaging from ‘Aging Technology, Emerging Threats: Examining Cybersecurity Vulnerabilities in Legacy Medical Devices’

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On April 1, 2025, the subcommittee on Oversight and Investigations of the House Committee on Energy and Commerce held a hearing on cybersecurity vulnerabilities in legacy medical devices. The hearing was largely a...more

Wiley Rein LLP

Trump Administration Revamps Guidance on Federal Use and Procurement of AI

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On April 3, the Office of Management and Budget (OMB) released two much-anticipated memos that will impact the use and procurement of artificial intelligence (AI) by the federal government, signaling an appetite to move...more

Sheppard Mullin Richter & Hampton LLP

FDIC Updates Crypto Guidance, Removes Pre-Approval Requirement for Banks

On March 28, the FDIC issued updated guidance clarifying the process for FDIC-supervised institutions to engage in crypto-related activities. The guidance rescinds and replaces prior instructions issued in 2022 and makes...more

Orrick, Herrington & Sutcliffe LLP

FDIC no longer requires notification of crypto-related activities

On March 28, the FDIC announced new guidance allowing FDIC-supervised institutions to engage in permissible crypto-related activities without prior approval. This update, outlined in FIL-7-2025, rescinded the previous...more

Mayer Brown

UK: Pensions – Updated Guidance on Employer Covenant Assessment

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AT A GLANCE - A new funding regime for defined benefit pension schemes in the United Kingdom came into force in September 2024. The new regime introduces a legal requirement for trustees to assess the strength of the...more

Wiley Rein LLP

FedRAMP Announces New Approach to Assessing Security of Cloud Services Providers, Leveraging Commercial Practices and Tools

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WHAT: FedRAMP has announced that it will be working on a new framework for authorization and assessment of cloud services for federal consumption, calling the initiative “FedRAMP 20X” (announcement here). In response to...more

Lowenstein Sandler LLP

SEC Updates Guidance on the Use of Gross and Net Performance in Advertisements

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On March 19, the Securities and Exchange Commission (SEC) issued a new FAQ response1 that softens prior guidance on the use of gross and net performance in advertisements. The new FAQs (the New Guidance) reduce the burden of...more

Rivkin Radler LLP

Quality of Care Considerations in OIG’s Nursing Facility Compliance Guidance

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In November 2024, the U.S. Department of Health and Human Services’ Office of the Inspector General (“OIG”) published the long-awaited Industry Segment-Specific Compliance Program Guidance for Nursing Facilities (“Nursing...more

A&O Shearman

SRB consultation on operational guidance on resolvability testing for banks

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The Single Resolution Board (SRB) has opened a consultation on its operational guidance on resolvability testing for banks under the SRB's remit. It aims to ensure that European banks are regularly testing their capabilities...more

Walkers

Central Bank Modernises Consumer Protection Code and introduces Standards for Business

Walkers on

Today, the Central Bank of Ireland published the Consumer Protection Code 2025 ("CPC 2025") comprising: (i) the Consumer Protection Code Central Bank Reform Act 2010 (Section 17A) (Standards for Business) Regulations 2025...more

Husch Blackwell LLP

Acting CFTC Chairman Caroline D. Pham Releases Additional Enforcement Guidance

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On March 11, acting Commodity Futures Trading Commission (CFTC) Chairman Caroline D. Pham offered insight into the regulator’s February 25, 2025 advisory in a keynote addressed delivered at Boca, the annual International...more

Morgan Lewis

CFTC Enforcement Replaces Previous Cooperation Guidance With New Mitigation Credit Matrix

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The Division of Enforcement of the US Commodity Futures Trading Commission (CFTC or Commission) recently issued an advisory revoking prior guidance for its staff in recommending enforcement resolutions (the Advisory) and...more

McDermott Will & Emery

FDA Reveals AI Development Cheat Sheet in Highly Anticipated Draft Guidances

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Early in the new year, the US Food and Drug Administration (FDA) released two anticipated draft guidance documents focused on artificial intelligence (AI): Artificial Intelligence-Enabled Device Software Functions: Lifecycle...more

Sheppard Mullin Richter & Hampton LLP

FedRAMP Releases New Draft Authorization Boundary Guidance

Over the last few years, the Federal Risk and Authorization Management Program (“FedRAMP”) Program Management Office (“PMO”) has released two draft guidance documents related to defining the applicable boundary for security...more

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