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UK Government Call For Evidence On Ownership And Control Test
The UK government, through the UK Office of Financial Sanctions Implementation (OFSI), has launched a call for evidence on the application of the ownership and control test under the UK Financial Sanctions Regulations. The OFSI seeks industry input on how the test operates in practice and where firms experience challenges in implementing the regulations....By: A&O Shearman
Institutional Investor Newsletter - Q1 2026
In 2026, evergreen funds are expected to rise further and the broadening of access to public markets will likely continue. Additionally, amid ongoing prevalence of liquidity solutions outside "traditional" exits, mergers and acquisitions dealmaking may bounce back. Despite increased positivity on exits, limited partners (LPs) will likely continue to sell fund interests on the secondary market at pace to gain liquidity and balance portfolios. Lastly, regulators are expected to continue focusing...By: DLA Piper
SEC Announces 45th Annual Small Business Forum
The Securities and Exchange Commission (the “SEC”) announced it will host its 45th Annual Small Business Forum (the “Forum”) on March 9, 2026 from 1:00 p.m. to 5:00 p.m. ET at the SEC’s headquarters in Washington, D.C....By: Mayer Brown Free Writings + Perspectives
NYSE American Proposes Significant Tightening of Initial Listing Standards
On January 8, NYSE American LLC filed a rule proposal with the Securities and Exchange Commission (SEC) that would materially tighten its initial listing standards in Sections 101 and 102 of the NYSE American Company Guide. If approved, the changes would bring NYSE American’s criteria much closer to the initial listing framework for Nasdaq listings, particularly around liquidity, public float composition, and minimum price requirements....By: Troutman Pepper Locke
EC Publishes Draft Delegated Regulations Under AMLD6 And AMLR
The European Commission (EC) has published two new webpages announcing the forthcoming adoption of two draft Delegated Regulations. The first, under Directive (EU) 2024/1640 (AMLD6), will set out the indicators for assessing the gravity of failures by member states to report adequate, accurate and up-to-date information to the central registers, including in cases of repeated failures....By: A&O Shearman
FATF Updates Regarding High-Risk Jurisdictions And Jurisdictions Under Increased Monitoring
The Financial Action Task Force (FATF) has published updates on high-risk jurisdictions and jurisdictions under increased monitoring. There are no changes to the high-risk jurisdictions, although the FATF notes where improvement is still required and confirms it may consider countermeasures if insufficient progress is made by June....By: A&O Shearman
Colony Ridge Settlement With Texas and US Department of Justice Reflects Shift in Enforcement Priorities
On March 6, 2026, a U.S. district court will consider whether to approve a settlement agreement resolving parallel lawsuits by the Texas attorney general (AG) and the federal government against Houston-area developer Colony Ridge Development, LLC and related companies. The complaints in both suits — which were filed during the Biden administration — claim that Colony Ridge discriminatorily targeted Hispanic consumers with predatory financing to purchase land for residences in areas that were in...By: Troutman Pepper Locke
SEC Staff Issues More CDIs on Exempt Offerings
In the second update to the Securities and Exchange Commission’s Division of Corporation Finance’s Compliance and Disclosure Interpretations in less than a week, on February 17, 2025, the Staff turned its attention to exempt offerings, focusing on Regulation A (“Reg A”) and Regulation Crowdfunding (“Reg CF”)....By: Mayer Brown Free Writings + Perspectives
[Audio] California DFPI's Next Target: Credit Reporting Industry — FCRA Focus
In this episode of FCRA Focus, host Kim Phan is joined by Michael Yaghi, partner in Troutman Pepper Locke’s Regulatory Investigations, Strategy, and Enforcement practice group, to unpack the California Department of Financial Protection and Innovation’s (DFPI) latest effort to require registration for the credit reporting industry. They discuss DFPI’s second request for comment, how it fits into California’s broader push to regulate nonbank financial services, and which entities may be swept in...By: Troutman Pepper Locke
Structured Finance Spectrum | Winter 2026
Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. This edition features shifts in loan-on-loan financing, the legacy of Bowie Bonds, and the return of the public RMBS deal....By: Alston & Bird
FinCEN Issues Exceptive Relief Order on Beneficial Ownership Verification Requirements
On February 13, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order granting exceptive relief to covered financial institutions from certain requirements under the 2016 Customer Due Diligence Requirements for Financial Institutions rule (2016 CDD Rule)....By: Goodwin
SRB Will Not Impose SRF Levies On Banks For 2026
The Single Resolution Board (SRB) has announced that, for the third consecutive year, it will not impose levies on banks to finance the single resolution fund (SRF). The SRF is an emergency fund that can be called upon in times of crisis. It can be used to ensure the efficient application of resolution tools for resolving failing banks, after other options, such as the bail-in tool, have been exhausted....By: A&O Shearman
Trump Administration Says CFPB Has Cost Consumers Hundreds Of Billions Of Dollars
Since its inception in 2011, the CFPB has cost consumers between $237 billion and $369 billion, the Trump Administration’s Council of Economic Advisers (CEA) said, in a report....By: Ballard Spahr LLP
UK OFSI Updates Financial Sanctions Enforcement Framework
The UK Office of Financial Sanctions Implementation (OFSI) is changing its enforcement approach....By: A&O Shearman
Cross-Border Securitization: 10 Things to Know About Securitizing Canadian Assets Into the U.S.
Cross-Border Securitization - Cross-border securitizations involving Canadian assets can take various forms. For example: • A U.S. originator may have sold products to Canadian customers and wants to include the related receivables (owing by Canadians) as part of an otherwise U.S. securitization. Please see full article below for more information....By: Blake, Cassels & Graydon LLP
Empower and Blackstone Walk Into a 401(k)… And It’s Not a Joke (But It Might Change Everything)
If someone had told me 15 years ago that one of the world’s largest alternative asset managers would be partnering with a mainstream retirement plan provider to bring private market investments into 401(k) plans, I would have assumed they were confusing a pension plan with a hedge fund cocktail party. Yet here we are....By: Ary Rosenbaum - The Rosenbaum Law Firm P.C.
EBA Final Guidelines On Proportionate Retail Diversification Methods Under CRR
The European Banking Authority (EBA) published final guidelines on proportionate retail diversification methods under Article 123(1) of the Capital Requirements Regulation (CRR). The guidelines seek to establish a harmonised and more proportionate framework for assessing whether retail portfolios qualify for the preferential 75% risk weight for retail exposures under the standardised approach for credit risk....By: A&O Shearman
FDIC and OCC release 2026 stress test scenarios
On February 12, the FDIC released hypothetical economic scenarios for upcoming stress tests applicable to covered institutions with total consolidated assets exceeding $250 billion, including certain state nonmember banks and state savings associations. According to the FDIC, the scenarios feature baseline conditions aligned with private sector forecasts and severely adverse conditions incorporating 28 variables, such as GDP, unemployment, stock market prices, and interest rates across domestic...By: Orrick, Herrington & Sutcliffe LLP
Ignorance of FBAR Reporting and Worldwide Income Disclosure is No Excuse for a U.S. Taxpayer
There are substantial challenges for U.S. taxpayers, expatriates, and foreign nationals and spouses who live and work in the United States, with offshore accounts, assets, investments, business interests, or income. Many were not aware the U.S. taxes all income, worldwide. U.S. taxpayers are required by law to understand and comply with all taxation-related requirements, including the FinCEN Form 114 (FBAR) and many IRS disclosure forms. Unfortunately, ignorance of FBAR reporting and worldwide...By: Allen Barron, Inc.
Navigating KYC and AML Compliance After FinCEN’s Beneficial Ownership Updates
Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements form the foundation of the United States’ framework for preventing money laundering, terrorist financing and other forms of financial crime. For banks, fintech companies, broker-dealers, and other regulated entities, these obligations are not simply regulatory formalities. They are core operational requirements that demand continuous oversight and board-level attention....By: Kohrman Jackson & Krantz LLP
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