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Cross-Border Transactions Broker-Dealer

Seward & Kissel LLP

SEC No-Action Relief Clears Operational Hurdles for Broker-Dealers Handling ETFs with Foreign Holdings

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Who may be interested: Exchange-Traded Funds, Broker-Dealers, Registered Investment Companies, Registered Investment Advisers, Compliance Staff, Boards of Directors - Quick Take: The Securities and Exchange Commission (the...more

McDermott Will & Schulte

CFTC Staff Letter 25-14: What Is a “U.S. Person”?

On May 21, 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division and Division of Market Oversight jointly issued Staff Letter 25-14 in response to a request from SCB Limited, a Bahamas-based...more

Latham & Watkins LLP

The Latham FPI Guide: Accessing the US Capital Markets From Outside the United States - 2021 Edition

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Fabry-Pérot Interferometer, SA is a highly successful non-US company known to the world as FPI. FPI is considering doing a debt or equity offering in the United States. What are the key legal issues it, and its underwriters...more

Dorsey & Whitney LLP

The Lights Could Go Out on Over-the-Counter Companies on September 28, 2021

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On September 28, 2021, companies trading in the United States over-the-counter securities markets (“OTC Markets”) that do not comply with amended Rule 15c-211 will no longer be eligible for quotation on the OTC Markets,...more

Ballard Spahr LLP

Treasury Department’s 2020 National Illicit Finance Strategy: Aspirations for BSA/AML Modernization and the Combatting of Key...

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First in a Two-Post Series - The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring the Lasted Guidance From the CFTC, the NFA and ESMA

BROKER-DEALER - FINRA Expands Transparency Initiative Related to OTC Equity Trading Volume - The Financial Industry Regulatory Authority (FINRA) previously announced an expansion to its ongoing transparency initiative...more

Katten Muchin Rosenman LLP

Bridging the Week - November 2019 #2

A social media company and its wholly owned subsidiary sued by the Securities and Exchange Commission for conducting an offering of an unregistered digital security claimed that the agency was wrong in its characterization of...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on the Latest Swap Regulations and Position Limits

DERIVATIVES - See also “CFTC Extends Public Comment Period for Proposed Rules Pertaining to Cross-Border Clearing” and “CFTC and European Commission Issue Joint Statement Following Meeting on Cross-Border Derivatives...more

Morgan Lewis

Fintech Writ Global—Takeaways from Cross-Border Fintech: Regulation & the Law 2019

Morgan Lewis on

We are always looking to identify good forums for keeping abreast of global fintech developments and trends. One such interesting platform was Cross-Border Fintech: Regulation & the Law 2019, held in London on June 6, where...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest - Volume XIV, Issue 21

BROKER-DEALER - FINRA Issues Regulatory Notice Reminding Member Firms about CAT Reporting Deadlines - On May 21, the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 19-19 (Notice), which reminds...more

Jones Day

Regulation Best Interest: The Next Big Thing for Broker-Dealer Cross-Border Private Wealth

Jones Day on

In April 2018, the U.S. Securities and Exchange Commission ("SEC") released Regulation Best Interest, or Reg BI, a proposed rule that will require broker-dealers to operate in the best interest of their customers. Under Reg...more

A&O Shearman

MiFID II, Research and Extraterritoriality: The SEC, European Commission and FCA Solution

A&O Shearman on

On October 26, 2017, the US Securities and Exchange Commission, European Commission and the UK Financial Conduct Authority released, in a coordinated manner, a series of significant orders and guidance to address some of the...more

Latham & Watkins LLP

MiFID II Research – Relief at Last?

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US and EU authorities have finally moved to solve the cross-border issues arising from MiFID II rules on research unbundling. Key Points: - The US SEC has published three temporary “no action” letters, which are...more

Skadden, Arps, Slate, Meagher & Flom LLP

Corporate Finance Alert: SEC Adopts T+2 Settlement Cycle for Securities Transactions

On March 22, 2017, the Securities and Exchange Commission (SEC) adopted an amendment to Securities Exchange Act Rule 15c6-1(a) to shorten the standard settlement cycle for most broker-dealer securities transactions from three...more

Goodwin

FinCEN Proposes AML Program Rule for Investment Advisers

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The Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would subject certain investment advisers to AML requirements under the Bank Secrecy Act (the BSA). In proposing the rule, FinCEN cited...more

Latham & Watkins LLP

Coming to America – A Guide for FPIs

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In this Issue: - The Latham FPI Guide: Accessing the US Capital Markets From Outside the United States - Chapter 1: Background - Chapter 2: Unregistered Global Offerings – Regulation S, Rule 144A and...more

Proskauer Rose LLP

Broker-Dealer Beat - December 2014 #2

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The SEC recently sanctioned another foreign bank for conducting cross-border brokerage activities without being registered. Since 2009, the SEC has sanctioned a number of foreign firms for failing either to register as a...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - July 19, 2013

In this issue: - SEC Extends Interim Final Temporary Rule for Broker-Dealers Engaging in a Retail Forex Business - FINRA Announces Targeted Examination Letter Regarding High-Frequency Trading - CFTC...more

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