Companies qualifying as “reporting companies” under the Corporate Transparency Act that were formed before 2024 have until December 31 to file their initial beneficial ownership information reports with the Financial Crimes Enforcement Network. With this deadline fast approaching, it is vital for all companies to determine whether they have a filing requirement or fall under
Regulation and compliance
UK PRA’s booking proposals – A step forwards or backwards?

In summer 2024, the Prudential Regulation Authority (PRA) published a Consultation Paper, CP11/24, on International firms: Updates to Supervisory Statement (SS5/21) and branch reporting. CP11/24 is key to understanding the booking models that the PRA will accept and reflects the debates which the branches of European banks have had in…
Global Asset Management Review: Issue 2
In the second issue of Global Asset Management Review, our cross-border team provide market updates followed by a closer look at some of the key issues impacting the asset management sector including:
The DOL’s fiduciary rule put on pause
On July 25, 2024, in the case of Federation of Americans for Consumer Choice, Inc., et al. v. United States Department of Labor, et al., (“Federation of Americans”) the United States District Court for the Eastern District of Texas issued an order staying the effective date of the DOL’s final fiduciary rule (and related amendments…
“Chevron is Overruled” Supreme Court decision upends the era of agency rule
The US Supreme Court’s ruling on the Chevron doctrine in Loper Bright Enterprises v. Raimondo (Loper), will profoundly impact multiple industries regulated by federal agencies that have grown accustomed to being the ultimate arbiter of ambiguous language in their applicable laws, rules and regulations. Those days are over—courts no longer have to defer…
Investigations Podcast Series – Episode 1: Early Stages of an Investigation
In the first episode of the Global Investigations Podcast Series, Andrew Reeves (Partner, Investigations, Enforcement and Compliance team, London) is joined by Ruth Cowley (Head of Disputes and Investigations, London), Keith Rosen (Head of Risk Advisory, US) and Sharon Oded (Head of Investigations, Amsterdam) to discuss the early stages of an investigation; best practice in…
Dealing with whistleblowing investigations in light of increased media and regulatory scrutiny
Introduction
Whistleblowing is on the rise – both within organisations and to authorities. An increase in whistleblowing is positive: it shows employees feel able to speak up, allows issues to be escalated, investigated and where necessary remediated. However, the increase in whistleblowing also presents challenges for companies to ensure that they are dealing effectively and…
SEC Strikes out on “Private Fund Advisers Rule”

In a unanimous decision, the United States Court of Appeals for the Fifth Circuit vacated the SEC’s “Private Fund Advisers Rule.” The Fifth Circuit determined that existing law did not provide the SEC the authority to issue rules covering private investment funds.
Read the full US Regulatory Intelligence article, SEC Strikes out on “Private Fund…
New Global Regulation Tomorrow Plus podcast: Consumer Duty – the annual governing body report
In our latest Global Regulation Tomorrow Plus podcast, Matthew Gregory, Joe Bamford, Hishaam Khan and Anita Edwards discuss the first annual governing body report, and the governing body’s obligations with respect to it, under the FCA’s Consumer Duty rules. Firms are required to have prepared the report by 31 July 2024, and in this podcast…
CFPB takes steps to regulate “Buy Now, Pay Later” providers

The Consumer Financial Protection Bureau (CFPB) on May 22, 2024 issued an interpretive rule that imposes some of the same rules on Buy Now, Pay Later (BNPL) providers that apply to conventional credit card providers. Specifically, the rule applies to digital user accounts used to access credit, including to those providers that market loans as…