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On May 11, 2018, the customer due diligence rule, 31 C.F.R. § 1010.230 (the “CDD Rule”), issued by the Financial Crimes Enforcement Network (“FinCEN”) became applicable two years...
As mid-year 2018 approaches, we have updated our brief deck summarizing the leadership and staffing changes among federal financial regulators, including announced nominations and resigna...
Notwithstanding the venerable status of the attorney-client privilege and the important purposes it serves, the federal banking regulators and the Consumer Financial Protection Bureau hav...
The SEC staff recently updated Compliance and Disclosure Interpretations (C&DIs) on the proxy rules and Schedules 14A/C. We understand that the SEC staff intends to review and change oth...
On May 9, 2018, in remarks to the New York City Bar Association’s Seventh Annual White Collar Crime Institute, Deputy Attorney General Rod Rosenstein announced a new Department of Justi...
The increased emphasis by the prudential banking agencies on recovery planning is evidenced by the Comptroller’s recent publication of a new recovery planning module for the Comptroller...
In an unusual finding, the Delaware Court of Chancery held that demand was partly excused and claims for corporate waste, bad faith and unjust enrichment could proceed against CBS Corpora...
On May 8, 2018, President Trump announced that he was terminating the United States’ participation in the Joint Comprehensive Plan of Action (“JCPOA”) with Iran and issued a Nationa...
A Cryptocurrency and DLT Newsletter – May 8, 2018 Authored by Avi Gesser, Jai R. Massari, Byron B. Rooney, Trevor I. Kiviat, Chad Richman, Zachary B. Shapiro, Mengyi Xu, Daniela Dekhtya...
The SEC recently proposed rules and interpretations seeking to enhance the standard of conduct of broker-dealers and investments advisers when they interact with retail investors. This a...