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Cleary Gottlieb Steen & Hamilton LLP

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Second Circuit decision clarifies framework for treatment of prepaid variable forward contracts under section 16

USA - January 23 2015 The Second Circuit Court of Appeals’ 2014 ruling in Chechele v. Sperling1, which addressed an issue of first impression among the Courts of Appeals

OFAC issues revised Cuban regulations

Cuba, USA - January 26 2015 On January 15, 2015, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC"), released revised Cuban Assets Control

Selected issues for boards of directors in 2015

USA - January 9 2015 As expected, 2014 proved to be a challenging year for boards. The legal and economic environments continued to grow more complex, and directors faced

Secretary of the Treasury proposes QFC recordkeeping rule

USA - February 17 2015 On January 7, 2015, the Secretary of the Treasury (the “Secretary”), as chairperson of the Financial Stability Oversight Council (“FSOC”) released a

The Kolassa case: jurisdictional issues for securities issuers and underwriters

European Union - March 16 2015 In an important judgment rendered on January 28, 2015 (case C-37513), the Court of Justice of the European Union ("ECJ") clarified for the first

Düsseldorf Court of Appeals upholds dismissal of CDC damage claims in cartel follow-on action

Germany - April 20 2015 Fourteen months after the Düsseldorf District Court (Landgericht Düsseldorf) had in a landmark decision dismissed cartel damage claims by Belgian

SEC adopts rules regarding reporting and dissemination of security-based swap information and proposes further amendments to the reporting rules

USA - April 20 2015 On February 11, 2015, the U.S. Securities and Exchange Commission (“SEC”) adopted rules regarding the regulatory reporting and public dissemination

Action required: how to update employee confidentiality provisions in light of recent SEC enforcement action

USA - April 20 2015 On April 1, the SEC announced its first enforcement action against a company for requiring employees to sign confidentiality agreements containing

COMESA amends thresholds and filing fees and issues final guidelines on merger review

Africa - April 16 2015 On April 8, 2015, following a meeting of the COMESA Council of Ministers, the COMESA Competition Commission (the “CCC”) announced amendments to

Iran sanctions: where are we and what’s next?

Iran, USA - April 6 2015 As has been widely reported, on April 2, 2015, the P51 powers, the European Union, and Iran announced a framework agreement for a “Joint