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Big Digital Apple – New York Adopts the 2022 UCC Amendments
Six months after being adopted by the New York State legislature, the 2022 Amendments to the Uniform Commercial Code (the “2022 Amendments”) were signed into law by Governor Hochul on December 5, 2025. New York becomes the 33rd UCC jurisdiction to enact the 2022 Amendments. The version of the amendments as enacted by New York (the “NY Amendments”) becomes effective 180 days after signing (on June 3, 2026 (the “Effective Date”))....By: Cadwalader, Wickersham & Taft LLP
UK Weekly Sanctions Update - Week of December 8, 2025
In this weekly update, we summarise the most notable updates in the UK sanctions world....By: Mayer Brown
OCC Issues Updated Venture Lending Guidance, Clarifies Risk Management Expectations
On December 5, the OCC issued updated guidance for banks on “venture loans” — commercial loans to companies in early, expansion or late stages of corporate development — rescinding its November 2023 bulletin of the same name (previously covered by InfoBytes here). The new bulletin maintained that there are generally higher risks associated with lending to early- and growth-stage companies but clarified that the OCC does not discourage prudent venture lending and that it is the responsibility of...By: Orrick, Herrington & Sutcliffe LLP
OCC Releases CRA Evaluation Schedule for First Two Quarters of 2026
Recently, the OCC released its schedule of CRA evaluations to be conducted in the first and second quarters of 2026. The agency encouraged public comment on the CRA-related activities of national banks and federal savings associations scheduled for evaluation, noting that all timely public input would be considered in the CRA evaluation process....By: Orrick, Herrington & Sutcliffe LLP
OCC and FDIC Rescind Old Guidance and Provide Eight Lending Points
On December 5, the OCC and FDIC rescinded the Interagency Guidance on Leveraged Lending issued in 2013 and the related FAQs from 2014, citing concerns that these documents were “overly restrictive and impeded banks’ application to leveraged lending of the risk management principles that guide their other business decisions.” The regulators noted past guidance contributed to a decline in banks’ leveraged lending market share and an increase in participation by nonbank entities that are not...By: Orrick, Herrington & Sutcliffe LLP
UK FCA Publishes Final Rules on Consumer Composite Investments Regime
The FCA has published a policy statement setting out its final rules for providing information on Consumer Composite Investments (CCIs). The new regime for CCIs is the replacement for the Packaged Retail and Insurance-based Investment Products (PRIIPs) regime and the Undertakings for Collective Investment in Transferable Securities (UCITS) disclosure requirements. These regimes will be replaced with a single framework tailored for UK consumers and markets....By: Hogan Lovells
[Video] FCPA Compliance Report - Kristy Grant-Hart on the Evolution of Compliance in 2026: Navigating New Risks and Regulation
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes Kristy Grant-Hart, Head of Advisory Services at Diligent’s Spark Compliance Group, to discuss where compliance has been in 2025 and where it is going into 2026. Tom Fox and Kristy Grant-Hart explore the future of corporate compliance in 2026 and beyond. Key discussion areas include the Trump administration’s changing focus on the Foreign Corrupt Practices Act (FCPA), the...By: Thomas Fox - Compliance Evangelist
[Video] Compliance Tip of the Day – Your Investigative Protocol
Welcome to “Compliance Tip of the Day,” the podcast that brings you daily insights and practical advice for navigating the ever-evolving landscape of compliance and regulatory requirements. Whether you’re a seasoned compliance professional or just starting your journey, we aim to provide you with bite-sized, actionable tips to help you stay on top of your compliance game. Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your...By: Thomas Fox - Compliance Evangelist
New Guidance on Non-Financial Misconduct: FCA Confirms Position
The FCA will be introducing new guidance to help firms deal with instances of non-financial misconduct....By: Latham & Watkins LLP
CFTC Announces Amendments to Rules of Practice and Rules Relating to Investigations
On December 1, 2025, Commodity Futures Trading Commission (the Commission or CFTC) Acting Chairman Caroline Pham announced a suite of changes to the Commission’s Rules of Practice and the Wells process outlined in the Commission’s Rules Relating to Investigations....By: WilmerHale
[Video] AI Today in 5: December 15, 2025, The Good, Bad & Ugly Edition
Welcome to AI Today in 5, the newest edition to the Compliance Podcast Network. Each day, Tom Fox will bring you 5 stories about AI to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the AI Today In 5. All, from the Compliance Podcast Network. Each day, we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest related to AI. Top AI stories include: • Data Sovereignty and AI compliance. (DataCentre):...By: Thomas Fox - Compliance Evangelist
Fed Updates Its Pricing for Payment Services
On December 4, the Fed announced the pricing for certain payment services provided by the Federal Reserve Banks, e.g., the clearing of checks, ACH transactions, instant payments, wholesale payment and settlement services, etc. In a notice published in the Federal Register, the Fed approved setting the private-sector adjustment factor (PSAF) for 2026 at $34.1 million and the 2026 fee schedules for Fed services and electronic access....By: Orrick, Herrington & Sutcliffe LLP
Application du taux de marché à un prêt intragroupe par voie de réclamation
Le Conseil d’Etat rend une décision sur une demande d’application de la règle dite du « taux de marché » prévue à l’article 212, I-a du Code général des impôts a posteriori sur réclamation du contribuable. Contrairement à l’administration qui a rejeté cette réclamation, le Conseil d’Etat rappelle que la société emprunteuse peut justifier du « taux de marché » par tout moyen et considère que la circonstance que les éléments justificatifs du taux pratiqué (en l’occurrence des offres de prêt)...By: Mayer Brown
Small Business Administration Orders All 8(a) Program Participants to Submit Financial Records for Fraud Review
On December 5, the U.S. Small Business Administration (SBA) announced it has directed all 4,300 firms participating in the 8(a) Business Development Program to submit financial records for the past three fiscal years. The required documents included bank statements, financial statements, general ledgers, payroll registers, contracting and subcontracting agreements, and employment records. The 8(a) Business Development Program is a federal initiative administered by the SBA to help small...By: Orrick, Herrington & Sutcliffe LLP
CFTC Launches Digital Assets Pilot Program and Issues Guidance on Tokenized Collateral
On December 8, the CFTC announced a series of actions to provide regulatory clarity and support responsible innovation in digital asset markets. Acting Chair Caroline Pham stated the actions implement recommendations from the president’s Working Group on Digital Asset Markets’ report (covered by InfoBytes here) and follow the CFTC’s Crypto Sprint initiative....By: Orrick, Herrington & Sutcliffe LLP
UK FCA Consults on Rule Changes for Client Categorisation and Conflicts of Interest
On 8 December 2025, the FCA published a consultation paper (CP) on client categorisation and conflicts of interest. This consultation will be of particular interest to wealth managers and investment firms, as it may enable them to change the way in which they categorise their clients. The FCA is also proposing to rationalise the conflicts of interest rules....By: Hogan Lovells
NCUA Proposes First Set of Regulatory Changes Under ‘Deregulation Project’
On December 10, the NCUA announced the first round of proposed regulatory changes as part of its new “Deregulation Project,” an initiative to review and potentially revise agency regulations to reduce burden and eliminate outdated requirements in response to Executive Order 14192 (covered by InfoBytes here)....By: Orrick, Herrington & Sutcliffe LLP
Bénéficiaire effectif et non-application d’un taux réduit de retenue à la source en présence de dividendes versés à une société luxembourgeoise et reversés à son actionnaire américain
Le Tribunal administratif de Paris valide la remise en cause par l’administration fiscale du taux réduit de retenue à la source de 5 % prévu par la convention franco-luxembourgeoise en présence de dividendes versés à une société luxembourgeoise et reversés à son actionnaire américain, au motif que la société luxembourgeoise n’était pas le bénéficiaire effectif des dividendes (TA Paris, 19 novembre 2025, n° 2400552 et 2400553)....By: Mayer Brown
Fed Requests Comment on the Future of Agency’s Check Services
On December 9, the Fed published an RFI in the Federal Register requesting public input on the future of the Fed’s check services. In its notice, the Fed will assess possible strategies for the future of checks, acknowledging that check usage in the U.S. has steadily declined over recent decades even as noncash payments increased. Strategies proposed by the Fed range from maintaining current operations without new investments, to simplifying and winding down check services to reduce costs, to...By: Orrick, Herrington & Sutcliffe LLP
CFPB Publishes Eight Notices on Reinstating OMB Requirements
On December 9 and 10, the CFPB published eight notices in the Federal Register requesting comment on reinstating OMB approvals for existing information collections. The CFPB invited comments as to whether the collection of information is necessary. It also sought input on the burden imposed by such collection....By: Orrick, Herrington & Sutcliffe LLP
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