Archive:March 2025

1
Europe: UK Sanctions Regulator Highlights Compliance Failures
2
United States: SEC’s Approach to Artificial Intelligence Begins to Take Shape
3
Australia: APRA Proposes Reforms to Strengthen Governance Standards
4
United States: New Kid on Y’all’s Block
5
United States: Trust But Verify (With A Minimum Investment Amount)

Europe: UK Sanctions Regulator Highlights Compliance Failures

By: Michael E. Ruck, Rosie L. Naylor, Petr Bartos, Helen J. Phizackerley, and Laura Scott

On 13 February 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) published an assessment of suspected sanctions breaches involving UK financial services firms since February 2022. It highlights three areas of concern:

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Australia: APRA Proposes Reforms to Strengthen Governance Standards

By: Jim Bulling, Simon Kiburg and Eddie Frost

The Australian Prudential Regulation Authority (APRA) has proposed reforms to strengthen core prudential standards and guidance on governance, currently set out in SPS 510 Governance, SPS 520 Fit and Proper, and SPS 521 Conflicts of Interest.

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United States: New Kid on Y’all’s Block

By: Stacy L. Fuller, Kevin R. Gustafson, Richard F. Kerr, Jessica D. Cohn, and Christine Mikhael

On 31 January 2025, the Texas Stock Exchange LLC (TXSE) filed a registration statement with the US Securities and Exchange Commission (SEC) to operate as a fully electronic, national securities exchange.

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United States: Trust But Verify (With A Minimum Investment Amount)

By: Pablo Man and Ruth Delaney

On 12 March 2025, the SEC staff issued a no-action letter for offerings under Rule 506(c) of Regulation D. In the letter, the Staff concurs that an issuer will have taken “reasonable steps to verify” a purchaser’s accredited investor status in an offering conducted under Rule 506(c) if the issuer requires purchasers to agree to certain minimum investment amounts, subject to a few additional conditions:

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