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ARRC Releases Recommended Fallback Language for Floating Rate Notes and Syndicated Loans

USA - May 23 2019 “It’s no longer a question of ifbut whenLIBOR will become unusable, yet most contracts referencing it don’t adequately account for this eventuality...

Michael L.Spafford, Scott Faga, Eugene Ferrer, Daren F. Stanaway, Joyce Xu, Diona Park, Michael Baker.

Can Cannabis Banking Work? Growing Interest in a Federal Safe Harbor

USA - May 1 2019 With over half of states legalizing cannabis for medical or recreational use,1 the legal cannabis industry in the United States grew to over $10.4...

Sara K. Weed, Kelsey Sullivan, Lara Kaplan.

Federal Reserve Board Proposes Codification of Control Principles from Lore into Law, Providing Greater Transparency to Potential Control Parties

USA - April 30 2019 Years of regulatory lore as to the factors that determine when a party is deemed to “exercise a controlling influence” over a bank holding company...

Kelsey Sullivan.

Sanctions Compliance Shortfalls Result in $1B Global Enforcement Action

USA - April 11 2019 On April 9, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the U.S. Department of Justice (“DOJ”), the New...

Kwame Manley, Jeremy Steed, Scott M. Flicker.

The EU Regulation of Crypto-assetsFit for Purpose?

European Union - April 9 2019 The European Union has said that current laws on the regulation of crypto-assets may not be “fit for purpose” and may need to be...

Arun Srivastava, Lara Kaplan, Nina Moffatt, Chris Daniel.