The Foreign Account Tax Compliance Act (“FATCA”) generally imposes registration, due diligence, withholding and reporting obligations on certain investment funds and investment fund managers. Under the U.S. Treasury regulations, foreign financial institutions (“FFIs”), including investment funds and investment managers that
Schulte Roth & Zabel LLP
Schulte Roth & Zabel LLP is a law firm that publishes blogs focusing on regulatory and compliance issues affecting financial services and investment management. Their content covers updates and analyses on securities laws, investment company regulations, sanctions, and financial industry rules such as the Volcker Rule and LIBOR transition. The firm provides insights into developments from regulatory bodies like the SEC, OFAC, and other financial regulators. Their publications aim to inform legal and financial professionals about changes in the regulatory landscape and their implications for investment funds, ETFs, and financial institutions.
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https://srz.com
Latest from Schulte Roth & Zabel LLP - Page 12
Funds Face New Sanctions, AML Risks in Wake of Escalating U.S.–Russia Tensions
The United States and others have imposed economic sanctions and issued anti-money laundering advisories in the wake of the growing political tensions between the United States and Russia over the fate of Ukraine. Click here for a summary of the actions…
Recent SEC Guidance on “Knowledgeable Employees” and Broker-Dealer Registration
The U.S. Securities and Exchange Commission recently released guidance on two matters involving “knowledgeable employees” and broker-dealer registration that are relevant to many private fund managers. These communications represent SEC responses to requests for guidance and relief from a number…
Do You Need to Make Changes to Your UK LLP Agreement?
In May 2013, HM Revenue and Customs (“HMRC”) consulted on proposals in two areas to tackle perceived tax avoidance via partnerships. The first area was disguised employment in Limited Liability Partnerships (“LLPs”) and the second was the tax-motivated allocation of…
CFTC SEF Update
By Craig Stein
Yesterday, the Commodity Futures Trading Commission (the “CFTC”) announced several important updates related to swap execution facilities (“SEFs”):
1. CFTC Website Location for MAT Swaps. The CFTC announced that it has published a centralized list of swaps subject to the swap execution…
Swaps Update: Mandatory Trading on SEFs Commences February 15 for Certain Interest Rate Swaps
By Craig Stein
The Commodity Futures Trading Commission (the “CFTC”) announced its first two “made available for trade” determinations (each, a “MAT Determination”), which mandate that fund managers trade certain benchmark interest rate swaps on behalf of their funds and managed accounts through…
Summary of Final Volcker Rule Regulation — Compliance Programs
On Dec. 10, 2013, the Commodity Futures Trading Commission (“CFTC”), Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (the “Board”), Office of the Comptroller of the Currency and Securities and Exchange Commission (“SEC”) (collectively, the “Agencies”) issued a final rule…
SEC Releases a Second Installment of “Bad Actor” Rule Guidance
Earlier this month, the Division of Corporate Finance (“CorpFin”) of the U.S. Securities and Exchange Commission supplemented — for the second time — its Compliance and Disclosure Interpretations (“C&DIs”) to address some of the questions raised by private fund managers…
Summary of Final Volcker Rule Regulation — Proprietary Trading
On Dec. 10, 2013, the CFTC, FDIC, Federal Reserve Board, OCC and SEC issued a final rule (the “Final Rule”) implementing Section 619 of the Dodd-Frank Act, which is commonly referred to as the “Volcker Rule.” The Volcker Rule restricts…
Summary of Final Volcker Rule Regulation — Fund Activities
On Dec. 10, 2013, the CFTC, FDIC, Federal Reserve Board, OCC and SEC issued a final rule (the “Final Rule”) implementing Section 619 of the Dodd-Frank Act, which is commonly referred to as the “Volcker Rule.” The Volcker Rule restricts…