Sidley Updates
New Executive Orders Assert Increased Control and Oversight Over SEC and Other Independent Agencies and Promote Deregulation
Sidley Resource
Securities Enforcement and Regulatory Resource Center
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CFTCCFTC Staff Advisory on Referrals to the Division of Enforcement
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FINRAFINRA Seeks Public Comment on Efforts to Modernize Member Workplace Rules
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Market StructureNorth American Securities Administrators Association Amends Its Model Business Conduct Rule
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SEC, Public CompaniesSEC Ends Defense of Climate-Related Disclosure Rules
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FINRAFINRA Seeks Public Comment on Proposed Changes to Rules Governing Outside Activities of Associated Persons
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FINRAFINRA Seeks Public Comment to Inform Rule Modernization Efforts
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CFTCU.S. CFTC Withdraws Swap Execution Facility Registration Advisory Effective Immediately
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SECSEC to Revive Clayton-Era Proposal to Regulate Venues Trading U.S. Treasuries
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CFTCU.S. CFTC Enforcement Advisory on Self-Reporting, Cooperation, and Remediation
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SECNew Executive Orders Assert Increased Control and Oversight Over SEC and Other Independent Agencies and Promote Deregulation
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FINRA, SECIncreased U.S. Regulatory Focus on Fully Paid Securities Lending Programs
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SECEngage With the U.S. SEC’s Crypto Task Force and Shape the Future of Crypto Regulation
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CFTCU.S. Commodity Futures Trading Commission Finalizes Margin Adequacy and Separate Account Treatment Rules
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SEC, CFTC, FINRAArtificial Intelligence: U.S. Securities and Commodities Guidelines for Responsible Use
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FINRAWith New Technologies Come New Risks: FINRA Issues 2025 Regulatory Oversight Report
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SECSEC Charges Musk With Late Filing, Punts on 13G Eligibility Issue
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SECSEC Amends Rule 15c3-3 to Require Daily Reserve Computations for Certain Broker-Dealers
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FINRANew FINRA Securities Loan Reporting Regime SLATE-ed for January 2026
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SECSEC Division of Enforcement Reports Overall Decrease in Enforcement Actions in 2024 Fiscal Year
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FINRAD.C. Circuit Enjoins FINRA from Expelling Member Before SEC Review
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Investment AdvisersFY2024 in Review: SEC Enforcement Actions Against Investment Advisers to Private Funds, Registered Funds, and Retail Clients
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SECUS SEC Division of Exams Announces 2025 Examination Priorities
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SECRisk Alert: SEC Staff Explains Risk-Based Approach to Registered Investment Company Examinations
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Market StructureSEC Adopts Rules Modifying Minimum Pricing Increments, Access Fee Caps, and Order Transparency
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Investment AdvisersCrypto-Focused Private Fund Adviser Settles with U.S. SEC for Custody Rule and Other Violations
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SECU.S. SEC Enforcement Director Grewal Offers Insights on Cooperation With Investigations
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SECU.S. Supreme Court Limits Use of SEC Administrative Courts in Antifraud Actions
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Investment AdvisersU.S. Fifth Circuit Court of Appeals Vacates Private Funds Rules: What’s Next?
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SECU.S. SEC Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Customer Information Amendments Adopted
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Investment AdvisersSEC and FinCEN Propose Customer Identification Program Rule for Registered Investment Advisers and Exempt Reporting Advisers
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FINRAFINRA Proposes Rules to Implement New Securities Lending and Transparency Engine (SLATE™)
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Investment AdvisersSEC EXAMS Alert Highlights Investment Adviser Marketing Rule Exam Deficiencies
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Market StructureSEC Adopts Amendments to Modernize Disclosure of Order Execution Information
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Investment AdvisersSEC Files First Charges Against Standalone Investment Adviser for Off-Channel Communication Recordkeeping Failures
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Public CompaniesIs Your Company Ready For the SEC’s New Climate Disclosure Rules? We Break Them Down.
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Public CompaniesSEC Finalizes Climate-Related Disclosure Rules Ushering in a New Era of Public Company Climate Reporting
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CFTCU.S. Commodity Futures Trading Commission Proposes to Modify and Codify Margin Adequacy Relief
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SECU.S. SEC Office of Credit Ratings Publishes Annual Staff Report on Nationally Recognized Statistical Rating Organizations
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CFTC, SEC2024 Derivatives Year in Preview
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Anti-Money Laundering, Investment AdvisersIT’S BA-ACK: FinCEN Issues Notice of Proposed Rulemaking for SEC Registered Investment Advisers and SEC Exempt Reporting Advisers
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Market Structure, SECU.S. SEC Expands Dealer Registration Requirements, Including to Certain Private Funds
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CFTCU.S. CFTC Seeks Public Input on Use of Artificial Intelligence in Commodity Markets and Simultaneously Warns of AI Scams
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FINRAIt Appears Everything Is a Risk: FINRA Issues 90-page 2024 Regulatory Oversight Report
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SECSEC Adopts Final Rules Regarding Special Purpose Acquisition Companies and De-SPAC Transactions
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FINRALong-Awaited Guidance on New Rules Regarding Residential Supervisory Locations and Remote Branch Office Inspections
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CFTCFifth Circuit Vacates U.S. Commodity Futures Trading Commission’s $6.5 Million Jury Verdict for Lack of Fair Notice
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SECU.S. SEC Adopts Rules Requiring Central Clearing in the U.S. Treasury Market
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SECConstitutional Challenges Shaping the Securities Regulatory Landscape
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SECU.S. SEC Finalizes Rule Prohibiting Certain Conflicts of Interest in Securitization Transactions
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Anti-Money LaunderingUpdates on U.S. Corporate Transparency Act Beneficial Ownership Reporting Requirements
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FINRAFINRA Settlements Focus on Disclosure and Appropriateness in Retail Customer Fully Paid Lending Arrangements
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CFTCCFTC Issues Proposed Guidance Regarding the Listing of Voluntary Carbon Credit Derivative Contracts
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Public CompaniesAction Items for U.S. Public Companies to Consider for 2024
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SECU.S. SEC Adopts Rules for Security-Based Swap Execution Facilities
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SECU.S. SEC Division of Enforcement Reports Increase in Actions and High Recoveries in 2023 Fiscal Year
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SEC, Market StructureU.S. SEC Proposes New Rule to Prohibit Certain Volume-Based Exchange Transaction Pricing
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SEC, Anti-Money Laundering, Investment AdvisersU.S. SEC Division of Exams Announces 2024 Examination Priorities
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CFTCU.S. CFTC Sends a Message: Higher Penalties, More Monitors and Consultants, and Fewer No-Admit/No-Deny Resolutions
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SEC, Market StructureNew SEC Rule Requires Extensive Reporting and Disclosure of Securities Lending Information
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SEC, Market Structure, Short Sales/Reg SHO“Get Shorty – The Sequel”: SEC Implements New Disclosure of Short Positions and Reliance on Bona Fide Market Making Exception
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SEC, Investment Advisers2023 Fiscal Year in Review: SEC Enforcement Actions Against Investment Advisers to Private Funds, Registered Funds, and Retail Clients
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CFTCCFTC Proposes First Major Changes to Rule 4.7 in Over 30 Years
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SEC, Public CompaniesSEC Shortens Filing Deadlines for Schedules 13D/G; Adopts Certain Other Amendments and Issues Guidance in Lieu of Other Proposals
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SEC, Investment AdvisersLatest Wave of SEC Off-Channel Communications Enforcement Actions: Five Takeaways
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SECSEC Adopts Amendments to the Names Rule Under the 1940 Act
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Public CompaniesSEC’s Cybersecurity Disclosure Rules Are Here. Is Your Company Ready to Comply?
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SEC, Insider TradingU.S. SEC Files Litigated Charges Against Broker-Dealer and Parent for Misleading Disclosures Relating to Information Barriers
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SEC, FINRAIncreased Focus on Partial Tender Offers and Compliance with Rule 14e-4
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Investment AdvisersSEC Marketing Rule Enforcement: Charges Against Nine Registered Investment Advisers Over Hypothetical Performance Advertising
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Market Structure, FINRAU.S. SEC Adopts Amendments to Expand FINRA Oversight of Proprietary Trading Firms
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Investment AdvisersU.S. SEC Adopts Significant Changes for Advisers and Private Funds
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Market Structure, Investment AdvisersSEC Proposes Sweeping New Rules on Use of Data Analytics by Broker-Dealers and Investment Advisers
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Anti-Money LaunderingU.S. SEC Division of Examinations Risk Alert Focuses on Broker-Dealers Anti-Money Laundering Program Compliance
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Public CompaniesU.S. SEC Public Company Cybersecurity Disclosure Regulation Finalized With Swift Effective Date
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SEC, Investment AdvisersSEC Adopts New Rule Amendments for Money Market Funds and Form PF Reporting Requirements for Large Liquidity Fund Advisers
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ESG, CFTCCybersecurity and Environmental Fraud Top Priorities of U.S. Commodity Futures Trading Commission Division of Enforcement
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FINRAD.C. Circuit Questions Constitutionality of FINRA Hearing Officers, Enjoins Disciplinary Proceeding
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SECWhat to Expect in SEC Rulemaking: Takeaways From the SEC’s Spring 2023 Regulatory Agenda
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SECSEC Adopts Rules to Prevent Fraud in Security-Based Swaps, Reopens Comment Period on Large Security-Based Swap Position Reporting
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SECU.S. SEC Replaces the Investment Grade Exceptions to Regulation M
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Investment AdvisersSEC Adopts Significant Form PF Amendments
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SEC, FINRARegulation Best Interest: Emerging Arbitration, Regulatory, and Enforcement Developments
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SEC, Public CompaniesNew SEC Rules Will Require More Detailed, Periodic Disclosure of Corporate Buybacks and Issuer Rule 10b5-1 Plans
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Market StructureSEC Shines Spotlight on Crypto Asset Securities Trading Systems and DeFi in Reopening Comments on Reg ATS Proposal
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SECU.S. Securities and Exchange Commission Proposes Three Rules Related to Cybersecurity, Reopens Comment for One Rule
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CFTC“Made Available to Trade” Determination for Certain Overnight Index Swaps Linked to USD Secured Overnight Financing Rate and GBP Sterling Overnight Index Average Proposed to Go Live June 1
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ESGSEC Announces $55.9 Million Settlement in First Action Brought by its Climate and ESG Task Force
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Investment Advisers, SECSEC Division of Exams Announces 2023 Examination Priorities
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Investment AdvisersSEC Division of Examinations Issues Risk Alert for Newly-Registered Advisers
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Investment AdvisersSEC Proposes Sweeping Revisions to Advisers Act Custody Rule
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Public CompaniesImplications of the SEC’s Recent Enforcement Action Against Activision Blizzard
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SECSEC Re-Proposes Rule Prohibiting Certain Conflicts of Interest in Securitization Transactions
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FINRAFINRA Issues 2023 Report on Its Examination and Risk Monitoring Program
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Market StructureSEC Proposes Rules Related to Minimum Pricing Increments, Access Fee Caps, and Transparency of Better Priced Orders
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Market StructureSEC Proposes Rule to Enhance Competition for Certain Individual Investor Orders
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Market StructureSEC Proposes Amendments to Modernize Disclosure of Order Execution Information
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Market StructureSEC Proposes Comprehensive Best Execution Framework for Broker-Dealers
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SEC, Insider Trading, Public CompaniesSEC Adopts Significant Changes to Rule 10b5-1 Trading Regime and Related Disclosures
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Investment AdvisersEnforcement Update: Recent SEC Actions Against Investment Advisers to Private Funds, Registered Funds, and Retail Clients
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SECSEC Overhauls Mutual Fund and ETF Shareholder Reports
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SECSEC Modernizes Broker-Dealer Recordkeeping Requirements
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Investment AdvisersU.S. Adviser Marketing Rule: Compliance Deadline Approaching, Exams to Follow
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FINRAFINRA Issues Revised Sanction Guidelines
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SEC, Public CompaniesFinal SEC Pay-Versus-Performance Rule Will Require Extensive New Disclosures in 2023 Proxy Statements
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FINRA, SECSEC Proposes to Expand FINRA Oversight of Proprietary Trading Firms
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SECSEC Adopts Rules Requiring Electronic Filing for Form 13F Confidential Treatment Requests
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SEC, Public CompaniesSEC Proposes Amendments to the Substantial Implementation, Duplication, and Resubmission Bases for Excluding Shareholder Proposals
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Investment AdvisersSEC Requests Comment on Regulation of Information Providers Under the U.S. Investment Advisers Act
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SECSEC to Require Electronic Filing of Forms 144 via EDGAR
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Insider TradingSDNY Files First Indictment Related to Insider Trading of NFTs While SEC Enforcement Expands Focus on Digital Assets Broadly
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ESG, Investment AdvisersSEC Proposes New ESG Disclosures for Investment Advisers and Funds
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CFTCCFTC Proposes Amendments to Mandatory Clearing Requirements for Interest Rate Swaps
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SECSEC Proposes to Expand Fund Names Rule
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SECD.C. Circuit Upholds SEC’s Market Data Infrastructure Rules, Paving the Way for Competing Consolidators
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SEC, Investment AdvisersWhat Fund Managers and Investors Should Know About the SEC’s Bold New Regulatory Agenda
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SECFederal Appeals Court Holds SEC Administrative Proceedings Are Unconstitutional
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ESG, SECSEC Brings First ESG-Related Action Since Creating Climate and ESG Task Force
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Insider Trading, Investment AdvisersSEC EXAMS Staff Identify Deficiencies in Adviser MNPI Controls
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SECSEC Takes Another Try at Removing Credit Rating References From Regulation M
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SECSEC Proposes Significant Expansion of Firms That Must Register as Dealers
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SECThe SEC Has Crypto in Its Crosshairs (Again)
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SECSEC Announces 2022 Examination Priorities: Private Funds, ESG, Retail, Cyber, Digital Assets Top the List
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ESGSEC Proposes Far-Reaching Rules for “Enhancement and Standardization” of Climate-Related Disclosures
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FINRAFINRA Issues Regulatory Notice on Failure to Supervise Liability for Chief Compliance Officers
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Anti-Money LaunderingUK Economic Crime (Transparency and Enforcement) Bill
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SEC, Short Sales/Reg SHO“Get Shorty” Again! — What You Need to Know About The SEC’s Proposed New Short Disclosure/Short Sale and Consolidated Audit Trail Requirements
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SECNewly Proposed SEC Cybersecurity Risk Management Rules and Amendments for Registered Investment Advisers and Funds
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FINRAFINRA Issues 2022 Report on Its Examination and Risk Monitoring Program
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SEC, Public CompaniesSEC Proposes to Shorten Beneficial Ownership Reporting Deadlines, Expand Scope — How Will It Affect You?
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Investment AdvisersSEC Proposes Significant Changes for Advisers and Private Funds
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SECSEC Proposes Significant Expansion of Regulation ATS
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SECSEC Chair: Sweeping New Cybersecurity Rules Are Coming Soon
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SECSEC Encourages Self-Reporting of Recordkeeping Violations Resulting From Employees’ Use of Personal Devices for Business Communications
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Anti-Money LaunderingFinCEN Proposed Rule Will Require Many Domestic and Foreign Entities to Report Beneficial Ownership Information to the U.S. Government
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Short Sales/Reg SHO, Investment AdvisersHedge Fund Adviser and Associated Individuals Pay Over $8 Million to SEC for “Causing” Reg SHO and Dealer Registration Violations
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Insider TradingImplications of SEC’s Recent Insider Trading Enforcement Action in SEC v. Matthew Panuwat
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FINRAFINRA Announces Impending Special Purpose Acquisition Company Sweep
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ESG“How to Be ESG” — A Registered Fund Board’s Guide to ESG Compliance
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Anti-Money LaunderingFinCEN Issues Government-Wide Priorities for Anti-Money Laundering and Counter-Terrorist Financing
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ESG“How to Be ESG” — A Private Fund’s Guide to ESG Compliance
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Short Sales/Reg SHO, FINRA“Get Shorty” – FINRA Requests Comment on Proposed Significant Changes to Short Position and Stock Loan Reporting
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Anti-Money LaunderingFinCEN Seeks Public Comments on Beneficial Owner Reporting Requirements
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Anti-Money LaunderingFINRA 2021 Report Reminds Firms Key AML Regulatory Expectations Center Around Risk
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FINRAFINRA Issues 2021 Report on its Examination and Risk Monitoring Program
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Anti-Money LaunderingCongress Rings in the New Year With Substantial Changes to Anti-Money Laundering Laws
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