News & Analysis as of

Enforcement Actions Reporting Requirements Financial Services Industry

DLA Piper

“Fair Banking” Executive Order Targets Politicized Debanking and Reputational Risk

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On August 7, 2025, President Donald Trump issued an Executive Order entitled “Guaranteeing Fair Banking for all Americans” (EO). The EO broadly prohibits banks and other financial institutions from engaging in “politicized or...more

Mayer Brown

UK Weekly Sanctions Update - Week of July 14, 2025

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RUSSIA SANCTIONS - UK Lowers Oil Price Cap on Seaborn Russian Crude Oil, OFSI publishes related FAQs: On July 18, 2025, the UK Government, alongside the EU, announced that it will lower to Oil Price Cap on seaborne Russian...more

Buchalter

New Colorado Money Transmission Act Parallels Key Provisions of CSBS Money Transmission Modernization Act

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Colorado has adopted a new Money Transmission Modernization Act (“Act”), replacing the old Colorado Money Transmitters Act...more

Clark Hill PLC

Right To Know - June 2025, Vol. 30

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Cyber, Privacy, and Technology Report - Welcome to your monthly rundown of all things cyber, privacy, and technology, where we highlight all the happenings you may have missed. State Action: North Dakota Passes Law...more

Troutman Pepper Locke

Recent SEC AML Enforcement Actions’ Impact on Compliance Efforts in the Cannabis Sector

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Investing in the cannabis industry is not without its risks, given the evolving regulatory landscape and the varying state and federal statuses of the product itself. The Financial Crimes Enforcement Network (FinCEN) has...more

Davies Ward Phillips & Vineberg LLP

A Strong Signal: AMF Adopts a Policy Supporting Self-Reporting and Cooperation

The Autorité des marchés financiers (AMF), the body responsible for enforcing Québec’s legislation concerning the financial sector, recently adopted a Self-Reporting and Cooperation Policy. The policy, adopted on May 20,...more

Jones Day

CFTC Operating and Enforcement Divisions Issue Advisory on Referrals to Enforcement Division

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On April 17, 2025, the Commodity Futures Trading Commission's ("CFTC") operating divisions ("Divisions") provided guidance in an advisory on the criteria they will use when determining whether to refer self-reported...more

Morgan Lewis

CFTC Staff Issue Advisory on Criteria for Referrals to the Division of Enforcement

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The staff of the US Commodity Futures Trading Commission (CFTC or Commission) on April 17, 2025 issued an advisory outlining the criteria the agency’s Market Participants Division, Division of Clearing and Risk, and Division...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

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

Mayer Brown

UK Weekly Sanctions Update - Week of March 31, 2025

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In this weekly update, we summarise the most notable updates in the UK sanctions world....more

A&O Shearman

UK Financial Intelligence Unit SARS report published

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The UK Financial Intelligence Unit (UKFIU) has published its annual report on suspicious activity reports (SARs) for the period between April 2023 and March 2024. The annual report structure has been updated due to a number...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

Cadwalader, Wickersham & Taft LLP

Amid Chaos, Regulatory Change Continues Apace, March 2025 - Lessons From the FCA’s Fine of Infinox Capital

The FCA has fined Infinox Capital, a London-based broker, for breach of MiFIR transaction reporting requirements. Infinox failed to submit reports for some 46,053 transactions executed by its single-stock CFD (contract for...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

Whiteford

Client Alert: CTA Enforcement Suspended – Key Updates on Filing Requirements

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On March 2, 2025, the U.S. Department of the Treasury t (“Treasury”) announced that it will not impose penalties, fines, or pursue enforcement actions against U.S. companies, citizens, or their beneficial owners for failing...more

Ruder Ware

Yo-Yo-Yo: CTA is Back

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The Corporate Transparency Act (CTA) and its reporting requirements are back in effect. This afternoon, a federal district court in Texas granted the U.S. government’s motion to stay (i.e., pause) the nationwide CTA...more

Proskauer - Regulatory & Compliance

SEC Extends Compliance Date for Short Sale Reporting Rule to 2026

On February 6, 2025, the SEC announced that it was providing a temporary exemption from compliance with Rule 13f-2 under the Securities Exchange Act of 1934 (the “Exchange Act”), which establishes a mandatory short reporting...more

Orrick, Herrington & Sutcliffe LLP

CFPB discusses repossessions in auto finance

On January 23, the CFPB published a report titled, “Repossession in Auto Finance,” which discussed auto loan repossession trends, drawing on data from a pilot program that started in February 2023. The report revealed...more

Mayer Brown Free Writings + Perspectives

ICI Urges SEC to Delay Short-Sell Reporting Rules Amid Compliance Uncertainty

The Investment Company Institute (ICI) has asked the Securities and Exchange Commission (SEC) in a comment letter to delay enforcement of its new short sale disclosure rules (the “Short Sale Final Rules”) until additional...more

Morrison & Foerster LLP

Extended Compliance Date for Recent Form PF Amendments

The new year always marks the start of a busy regulatory filing season for registered investment advisers, including investment advisers that file Form PF (“Form PF Filers”). This year could be especially challenging since,...more

A&O Shearman

Updates on OJK Regulation 45/2024

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On December 27, 2024 the Indonesia Financial Service Authority (Otoritas Jasa Keuangan or the OJK) issued OJK Regulation No. 45 of 2024 on Development and Enhancement of Issuers and Public Companies (OJK Regulation 45/2024). ...more

WilmerHale

Keeping Up with the Regulators: How to Build an Effective Compliance Programme to Satisfy the Best Interest Care Obligation

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It has been nearly five years since the US Securities and Exchange Commission (‘SEC’ or ‘the Commission’) adopted Regulation Best Interest (Reg BI) to enhance the standard of conduct applicable to broker-dealers when they...more

DLA Piper

Blockchain and Digital Assets News and Trends – January 2025

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This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets. While the use cases for blockchain...more

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