On October 7, 2026, the U.S. Department of the Treasury (Treasury) announced that it had issued the first civil monetary penalty under the Outbound Investment Security Program (OISP) in July 2026.[1] Treasury penalized Amidi, LLC (Amidi), a U.S. entity,
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Antitrust Review Episode 70: In Conversation With the Booking/eTraveli Team
In our latest Antitrust Review podcast, host Nick Levy hosts a panel discussion of the European General Court’s judgment upholding the European Commission’s landmark prohibition of the Booking/eTraveli transaction. Enrique Gonzalez-Diaz, who represented Booking before the Court, Chris Cook, Anita
SEC Rescission of the Pay-to-Play Rule: How Much Better Off Are Investment Advisers?
The proposed rescission of Rule 206(4)-5 (the Pay-to-Play Rule) under the Investment Advisers Act of 1940 (the Advisers Act) by the Securities and Exchange Commission (the SEC) has generally been celebrated by industry participants and observers. However, the relief may
Reminder: September 30 EDGAR Next Annual Confirmation Deadline Approaching!
Since the EDGAR Next transition went live last year, SEC filers have had to adjust to a new set of account management obligations. Among these is the annual confirmation requirement; each year, one of a filer’s account administrators must log
SEC Proposes to Modernize Proxy Solicitation Rules
On September 16, 2026, the SEC proposed a package of amendments intended to modernize the federal proxy solicitation rules. The proposal targets several paper-era or otherwise outdated requirements whose original rationale has largely been displaced by EDGAR, electronic communication and
SEC Proposes to Rescind Rule 14a-8 and Amend Rule 14a-4: What This Means for Issuers
On September 16, 2026, the SEC issued its much-anticipated proposal to rescind Rule 14a-8 under the Securities Exchange Act of 1934 (the Exchange Act), the shareholder proposal rule, in its entirety. If adopted, the proposal would eliminate the federal framework
EC Recalibrates Guidance for Abuse of Dominance Under Article 102 TFEU
On September 3, 2026, the European Commission (EC) adopted Guidelines on the application of Article 102 TFEU to abusive exclusionary conduct by dominant undertakings (the Guidelines).
CMA Secures Compensation for Heating Oil Customers Following Unfair Order Cancellations During Price Spike
The Competition and Markets Authority (CMA) announced that it has secured compensation for off-grid domestic heating oil customers whose orders were unfairly cancelled following severe wholesale price shocks.[1]
Financing the Data Center Boom: The Investment Opportunity, the Risks, and the Capital Solutions Taking Shape
This is the first in a series of articles examining the rapidly evolving landscape of data center financing. Future installments will take a closer look at specific capital solutions — including senior secured bonds, structured joint ventures, project finance, and
Antitrust Review Episode 69: In Conversation With Andrew Ferguson
In our latest Antitrust Review podcast, host Nick Levy is joined by Andrew Ferguson, Chair of the U.S. Federal Trade Commission. Their conversation covers an array of topics, including the objectives of antitrust enforcement, America First Antitrust, the consumer welfare