Further measures have been taken against the Russian Federation by the United States and its allies since our last Russia-Related Sanctions Update. These recent measures include additional sanctions against the Russian...more
Russia first invaded Ukraine in February 2014. This latest invasion started on February 24, 2022. As of mid-April 2022, over 750 international companies have publicly announced plans to curtail or shut down operations...more
On March 30, 2022, the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations (the “Division”) issued its annual examination priorities for 2022. The Division will prioritize five significant focus areas...more
Executive Order 14071 “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to continued Russian Federation Aggression” - April 6, 2022 -
Executive Order 14071 (“EO 14071”) blocks any...more
The United States, primarily through Presidential action under the statutory authority of the International Emergency Economic Powers Act (“IEEPA”), has empowered the U.S. Department of the Treasury and its Office of Foreign...more
2/24/2022
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Effective January 10, 2022, the Federal Deposit Insurance Corporation (“FDIC”) issued a final rule (the “Primary Purpose Rule”) that adds a specific business relationship that qualifies under the Primary Purpose Exception...more
On December 14, 2021, the U.S. Office of the Comptroller of Currency (“OCC”) adopted a new final rule (“Final Rule”) under the Community Reinvestment Act of 1977, as amended (the “CRA”) which will be effective on...more
On July 20, 2021, the Board of Governors of the Federal Reserve System (the “FRB”), the Federal Deposit Insurance Corporation (the “FDIC”), and Office of the Comptroller of the Currency (“OCC”, and collectively with the FRB...more
On July 21, 2021, the Securities and Exchange Commission (the “SEC”), Division of Examinations (the “Division”), issued new guidance regarding “Fixed Income Principal and Cross Trades by Investment Advisers from an...more
The amount of capital that companies can raise in a Regulation A (also known as a “Reg A+”) offering increased to $75 million annually, effective as of March 15, 2021. With the new offering limit, Tier 2 Reg A+ offerings,...more
Effective April 1, 2021, the Federal Deposit Insurance Corporation (“FDIC”) launched a “Brokered Deposit” bankers’ resource web page, concurrently with the effective date of its final rule (the “Rule”) to modernize the...more
The New York State Department of Law recently adopted regulations (“NY IAR Regs”) that, starting February 1, 2021, require Investment Adviser Representatives (“IAR”) representing a New York state registered investment adviser...more
On December 22, 2020, the SEC finalized rules governing investment adviser marketing and payments to solicitors under the Investment Advisors Act of 1940, as amended. The reforms create a single rule to replace the current...more
On December 15, 2020, the Federal Deposit Insurance Corporation (“FDIC”) issued a final rule (the “Rule”) to modernize its regulations that implement Section 29 of the Federal Deposit Insurance Act (“FDI Act”). The FDIC...more
Introduction -
We often hear from hedge fund and private equity sponsors that private funds are too limiting for their capital formation needs. Private funds are collective investment vehicles that rely on the Section...more
The US Securities and Exchange Commission (SEC) has proposed to amend and modernize certain rules under the Investment Advisers Act that deal with investment adviser advertising and payments to solicitors. The proposed...more
On June 5, 2019, the Securities and Exchange Commission (the “SEC”) voted to adopt two new rules intended to protect retail investors. ...more