The AIFMD Third Country Passport – An Update

On September 30, 2026, the Securities and Exchange Commission (SEC) issued two rule proposals and five notices aimed at expanding investors’ access to private markets. The package would add ways to qualify as an accredited investor, including passing a new exam administered by the Financial Industry Regulatory Authority (FINRA), broaden performance-based compensation and modernize regulated funds, including interval funds and business development companies (BDCs).

The SEC has approved new NYSE and NYSE American listing rules establishing a $0.25 minimum trading price, effective July 1, 2027. A single closing price below this threshold triggers immediate trading suspension and delisting proceedings with no cure period. Companies trading at low share prices must act now during the transition period to implement reverse stock splits and establish monitoring procedures before this hard floor takes effect.

The U.S. Securities and Exchange Commission has proposed Regulation Crypto Assets, introducing two new exemptions from registration requirements and a safe harbor provision for investment contracts involving crypto assets. How will these tailored frameworks—the Startup Exemption for offerings up to $5M and the Fundraising Exemption for larger capital raises—reshape the regulatory landscape for digital asset issuers while preserving investor protections?

The SEC and CFTC have issued coordinated regulatory relief measures that significantly advance crypto-based trading infrastructure in US markets, bypassing Congressional gridlock on the CLARITY Act. These orders establish new frameworks for tokenized securities venues and passive software providers, potentially reshaping how digital assets are traded and accessed in regulated markets.

Moore & Van Allen's Derivatives & Trading team provides comprehensive analysis of recent CFTC and SEC enforcement actions, proposed regulations on crypto assets...

As AI infrastructure spending surges toward $697 billion in 2026, hyperscalers and compute providers are increasingly turning to debt, structured financing, and GPU-backed collateral to fund expansion. While demand projections remain bullish, a critical timing gap is emerging between capital deployment and cash flow generation, creating significant risks for lenders, sponsors, and operators across the ecosystem.

The SEC has issued a groundbreaking Innovation Exemption allowing tokenized securities venues to facilitate trading of tokenized NMS stocks using automated market makers and liquidity pools. This temporary five-year exemption from exchange and dealer registration requirements establishes conditions for permissioned blockchain-based trading while granting public companies a 30-day window to object to third-party tokenization of their securities.

The Health Resources and Services Administration has announced a revised 340B Rebate Model Pilot Program for drugs subject to Medicare's Maximum Fair Price, expanding eligibility to manufacturers with selected drugs for 2026 and 2027. The program introduces new data requirements, dispute resolution mechanisms, and stricter compliance monitoring while addressing stakeholder concerns about administrative burden and program integrity.

On March 19, 2026, the federal banking agencies issued a package of proposed changes to the regulatory capital requirements for banking institutions of all sizes, from the largest GSIBs and super-regional banks to community banks (the “Proposed Rules”). This package of proposals is a second full attempt at implementing the 2017 “Basel III Endgame” international framework—following the agencies’ initial package of proposals in July 2023 (the “2023 NPR”)—to better reflect credit, trading and operational risk in the calculation of minimum regulatory capital ratios.

Medicare Advantage faces unprecedented regulatory scrutiny as federal agencies deploy aggressive audit strategies, Congress investigates alleged fraud schemes, and courts challenge CMS's authority over payment structures.

As we look ahead to 2025, the landscape of debt financing and M&A activity is poised for significant transformation.

On June 1, 2023, China's Ministry of Science and Technology (the "MOST") issued the long-awaited Implementing Rules on the Administrative Regulations on Human Genetic Resources...

A sentencing hearing is scheduled before U.S. District Court Judge Loretta A. Preska on March 19, 2019.

On 31 October 2025, the Financial Conduct Authority (FCA) published the outcome of a multi-firm review into consolidation across the financial advice and wealth management sector.

The UK National Crime Agency (NCA) has successfully defended the first challenge to its new power to require individuals to explain how they have acquired assets which it suspects may represent the proceeds of crime.

In the United States Supreme Court’s historic decision announced today, the Patient Protection and Affordable Care Act ("ACA") has emerged substantially intact as the blueprint for national health reform in the coming years.

China will launch further reforms in the pharmaceutical sector as part of the healthcare reform initiatives announced by the State Council in its February 9, 2017 Circular on Several Opinions Concerning Further Reforms of the Policies Governing Drug Production, Circulation and Usage (the "Circular No.13").

Today, the Patent Trial & Appeal Bord designated two decisions informative that apply the so-called "Fintiv factors."

Yesterday saw another big addition to the U.S. UFLPA Entity List, the largest to date. The Department of Homeland Security, on behalf of the Forced Labor Enforcement Task Force...

Extradition from Japan is rare, and even more so for Japanese nationals in connection with white collar offenses. But on April 17, 2019,