Regulatory & Compliance

Regulatory & Compliance

Rita M. Molesworth, Dianne E. O'Donnell, Deborah A. Tuchman, Neesa P. Sood | Willkie Farr & Gallagher LLP

Commodity Futures Trading Commission Rule 4.5 provides an exclusion from the definition of “commodity pool operator” (CPO) for, among others, certain registered investment companies that trade commodity interests. Between late 2003 and the beginning of 2012, all registered investment...

Litigation

David S. Frankel | Kramer Levin Naftalis & Frankel LLP

In a July 1, 2013 decision of apparent first impression, Eastern District Judge John Gleeson held that district courts have authority to review substantively, and to determine whether to approve or reject, deferred prosecution agreements. In United States v. HSBC Bank USA, N.A. and HSBC Holdings...

Anti-Corruption

Jonathan Zdimal | KPMG LLP

Editor: How are companies responding to increased global regulatory coordination and sophistication with regard to anti-bribery and corruption (“ABC”) enforcement efforts? deGrasse: The government’s enforcement efforts certainly have become more sophisticated. The DoJ and SEC...