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CFTC Issues No-Action Relief on Cross-Border Swap Definitions for Investment Managers

The Commodity Futures Trading Commission (CFTC) has issued no-action relief permitting reliance on the 2020 Cross-Border Rule’s definitions of “U.S. person” and “guarantee” for certain cross-border swap requirements. Our Investment Funds Team highlights the practical implications for counterparty representations, compliance processes, and regulatory alignment....By: Alston & Bird

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New York LLC Transparency Act to Take Effect on January 1

New York’s Limited Liability Company Transparency Act (NYLLCTA), set to take effect on January 1, 2026, will require beneficial ownership reporting by certain limited liability companies. However, it’s unclear which LLCs will need to report. The NYLLCTA incorporates the definitions of “beneficial owner” and “reporting company” from the federal Corporate Transparency Act (CTA), but the CTA definitions were amended in an interim final rule issued by the U.S. Treasury’s Financial Crimes Enforcement...By: Rivkin Radler LLP

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SEC Staff Issues Helpful Guidance on Custodying Digital Asset Securities and Complying with the Customer Protection Rule

On Wednesday, December 17, the SEC’s Division of Trading and Markets (Division) issued a helpful statement (the Statement) to clarify its views on how a broker-dealer can meet its obligation pursuant to paragraph (b)(1) of Rule 15c3-3 of the Securities Exchange Act of 1934, as amended (the Customer Protection Rule), with respect to digital or crypto assets that are securities that a broker-dealer may carry for the accounts of its customers....By: Katten Muchin Rosenman LLP

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Alabama Supreme Court Appellate Alert: Decisions from December 19, 2025

The Alabama Supreme Court issued its weekly release list on Friday, December 19, which included the following opinions of interest to the Alabama business community......By: Maynard Nexsen

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New York State Clarifies Steps for Discharging a Mortgage in New Law

On December 12, the governor of New York signed into law amendments to the state’s real estate laws to clarify procedures for discharging a mortgage. The legislation revised the law to require mortgagees to accept and promptly apply any payment received at the specified location and in the manner specified by the mortgagee....By: Orrick, Herrington & Sutcliffe LLP

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What the CFPB’s New Buy Now, Pay Later Market Report Shows

The Consumer Financial Protection Bureau (CFPB or Bureau) released a new market “data spotlight” on Buy Now, Pay Later (BNPL) that uses actual transaction data from six large providers of “pay-in-four” BNPL loans. The report paints a picture of growing adoption paired with improving credit performance: late fees fell and charge-off rates declined in 2023, even as the number of loans and users rose....By: Troutman Pepper Locke

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UK FCA Letter Outlines 2026 Growth Strategy and Regulatory Reforms to Prime Minister

The UK Financial Conduct Authority (FCA) has sent a letter to the Prime Minister providing an update on its growth strategy. It confirms delivery of most of the 50 pro-growth measures announced in January and outlines plans for 2026. The plans include finalising rules on stablecoins, setting out the delivery plan for open finance, reforming rules for venture capital and alternative investment fund managers and further speeding up IPO applications....By: A&O Shearman

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Regulation Amending CRR ITS On Operational Risk Supervisory Reporting Of Institutions Published In OJ

Commission Implementing Regulation 2024/2475 has been published in the Official Journal of the European Union (OJ). The regulation makes amendments in relation to the implementing technical standards (ITS) on operational risk supervisory reporting of institutions for the purposes of article 430(7) of the Capital Requirements Regulation (CRR). The ITS specify uniform reporting formats and IT solutions, including instructions, for supervisory reporting requirements of institutions....By: A&O Shearman

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IRS Proposed Regulations Would Narrow the Exemption For Passive Income of Foreign Governments Under Section 892

The Internal Revenue Service (IRS) and the U.S. Treasury Department last Friday released final and proposed regulations addressing various rules under section 892. The rules are a mixed bag – some are favourable and provide clarity, while others may be unfavourable – and ambiguity may lead taxpayers to take more conservative positions. In particular, the proposed regulations would broadly treat debt acquisitions, whether or not at original issuance, as commercial activities, with limited safe...By: Davies Ward Phillips & Vineberg LLP

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Has Ransomware Peaked? FinCEN Data Shows Slight Downward Trend In Incidents.

The U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) released its latest Financial Trend Analysis (FTA) this month, reporting data from banks and other financial institutions showing that, following a recent surge, the number of reported ransomware incidents and payment amounts dipped slightly in 2024. High-profile ransomware attacks frequently appear in the news and the impact can be severe: in just the last month, news broke that an e-tailer company was knocked...By: Ballard Spahr LLP

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UK FCA Consults On Clarification Of Rules And Guidance As Part Of The Consumer Duty Requirements Review

The UK Financial Conduct Authority (FCA) has published consultation paper CP25/37, as part of the consumer duty requirements review and the workplan announced in the March feedback statement. The FCA sets out targeted amendments to reduce the administrative burden on firms in respect of UK UCITS investment powers, chapters 6 and 7 of the Client Assets Sourcebook, and certain changes to rules relating to insurance products and funeral plans....By: A&O Shearman

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Prediction Market Platforms Launch Coalition Focused on Federal Oversight Issues

Popular prediction markets platforms recently announced that they have formed the Coalition for Prediction Markets. According to the coalition’s website, it aims to unite exchanges, brokers, and advocates to expand consumer access to safe, transparent, and integrity-driven prediction markets in the U.S....By: Troutman Pepper Locke

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SEC Brings Cybersecurity and Identity Theft Controls Case Against Registered Investment Adviser and Broker-Dealer

On Nov. 25, the Securities and Exchange Commission (SEC) announced a settlement with a registered investment adviser (RIA) and broker-dealer (the Adviser) for violations of Regulation S-P and Regulation S-ID. Regulation S-P (17 CFR § 248.30) requires broker-dealers and RIAs to adopt written policies and procedures with administrative, technical, and physical controls to protect customer information. These policies must reasonably (1) ensure the security and confidentiality of customer...By: Lowenstein Sandler LLP

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[Video] Sunday Book Review: December 21, 2025, The Best Books on Compliance Edition

In the #SundayBookReview, Tom Fox considers books that would interest compliance professionals, business executives, or anyone curious. It could be books about business, compliance, history, leadership, current events, or anything else that might interest Tom. Today, we continue our review of some years’ top books in various categories. In this episode, we look at a book on compliance that Tom Fox selected. 1. Bribery Beyond Borders by Severin Wirz 2. Risk in Action by Jim Massey 3. Doing...By: Thomas Fox - Compliance Evangelist

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[Video] 10 For 10: Top Compliance Stories For the Week Ending December 20, 2025

Welcome to 10 For 10, the podcast that brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance, brings you the compliance stories you need to know to end your busy week. Sit back, and in 10 minutes, hear about the stories every compliance professional should be aware of from the prior week. Every Saturday, 10 For 10 highlights the most important news, insights, and analysis for the compliance professional, all curated by the Voice of Compliance,...By: Thomas Fox - Compliance Evangelist

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FDIC Seeks to Establish Pathway for Subsidiaries of Insured Banks to Issue Payment Stablecoins

The Federal Deposit Insurance Corporation (FDIC) has issued a Notice of Proposed Rulemaking (NPR) to establish procedures for an insured depository institution (state-chartered insured banks that are not members of the Federal Reserve System and state-chartered savings associations) to become approved to issue payment stablecoins through a subsidiary pursuant to the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). Comments on the proposal are due 60 days after...By: Stinson LLP

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UK FCA Consults on Recalibrating Client Categorisation and Rationalising Conflicts of Interest Rules

The UK Financial Conduct Authority published a package of consumer investments reforms on 8 December 2025 to empower retail investment and reinforce wholesale markets. At the heart of the proposals is the FCA’s ambition to rebalance risk in a way that supports growth, innovation and competitiveness....By: Morgan Lewis

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SFO Publishes Updated Annual Report on Whistleblowing Disclosures for 2024–25

On 28 November 2025, the Serious Fraud Office (SFO) published its annual report on whistleblowing disclosures and updated its guidance titled “Information for Whistleblowers”. While the guidance itself remains unchanged, the accompanying Report reflects a shift towards greater transparency compared to previous years. Last year’s publication focused primarily on headline numbers; this year, the SFO has provided more detail on how disclosures were handled....By: Hogan Lovells

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EU Fast-Tracks New Russia and Belarus Sanctions while Indefinitely Immobilizing Russian Sovereign Assets

While discussions surrounding the adoption of a more substantive 20th “package” of sanctions in response to Russia’s war in Ukraine continue, the European Union has moved forward with the imposition of additional restrictive measures targeting (i) Russia’s energy sector and shadow fleet enablers, and (ii) hybrid threats posed by Russia and Belarus....By: Mayer Brown

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2025 Has Been a Strong Year for IPOs. The 2026 Outlook is Even Stronger.

Moore & Van Allen (MVA) Head of International Capital Markets John I. Sanders and Corporate Associate Noah Edmondson co-authored the article, “2025 Has Been a Strong Year for IPOs. The 2026 Outlook is Even Stronger.”...By: Moore & Van Allen PLLC

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