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  • Article

    BIS Expands Export Restrictions To Foreign Companies 50% Or More Owned By Listed Entities

    The U.S. Department of Commerce's Bureau of Industry and Security ("BIS") has published a 50% rule (the "Affiliates Rule") that significantly expands U.S. export restrictions.
    United StatesInternational Law
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    California Regulator Fines Honda $632,500 For Privacy Violations

    On March 12, 2025, the California Privacy Protection Agency, in its first order of decision under the California Consumer Privacy Act of 2018 (as amended), fined American Honda Motor Co., Inc. $632,500 for CCPA violations …
    United StatesPrivacy
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    The SEC’s Proposed “Regulation Crypto Assets” Offers Clarity And Options To Crypto Issuers

    On August 18, 2026, the Securities and Exchange Commission (the “SEC”) released its “Regulation Crypto Assets” framework aimed at providing regulatory clarity for issuers of crypto assets. If finalized in its current form, the new rules would create two exemptions from the registration requirements of Section 5 of the Securities Act of 1933 (the “Securities Act”) for offerings involving crypto assets that are “investment contracts” under the federal securities laws.
    United StatesTechnology
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    EU Securitisation Reforms – May 2026

    On 5 May 2026, the European Parliament (the “Parliament”) voted in favour of certain reforms to the Regulation (EU) 2017/2402 (the “Securitisation Regulation”) (the “Reforms”).
    European UnionFinance and Banking
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    Treasury Proposes Section 162(m) Regulations To Effect Increase In Number Of "Covered Employees" Starting In The 2027 Tax Year

    On January 14, 2025, the Internal Revenue Service (IRS) and Department of the Treasury released proposed regulations under Section 162(m) of the Internal Revenue Code (Section 162(m)), which limit the ability of public corporations ...
    United StatesTax
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    New Guidance From The SEC's Division Of Trading And Markets Signals A Welcome Shift On The SEC's Approach To Crypto Asset Activities And Distributed Ledger Technology

    In a major development, the Staff of the Division of Trading and Markets of the U.S. Securities and Exchange Commission (the "SEC" or the "Commission") released a new set of Frequently Asked Questions (the "FAQs")...
    United StatesCorporate/Commercial Law
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    SEC Watch: Monthly Takeaways For Asset Managers - April 2026

    The SEC and the CFTC jointly announced that they entered into a Memorandum of Understanding “to guide coordination and collaboration between the two agencies to support lawful innovation, uphold market integrity, and ensure investor and customer protection.” As managers well know, the two agencies’ overlapping jurisdiction has at times led to duplicative and often conflicting regulatory schemes, as well as enforcement investigations and resolutions covering essentially identical conduct.
    United StatesCorporate/Commercial Law
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    SEC Watch: Monthly Takeaways for Asset Managers - April 2026

    Summary: The SEC and the CFTC jointly announced that they entered into a Memorandum of Understanding “to guide coordination and collaboration between the two agencies to support lawful innovation, uphold market integrity, and ensure investor and customer protection.”
    United StatesCorporate/Commercial Law
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    DOJ Criminal Division Unveils New Guidance On Self-Reporting And Enforcement Priorities For Corporate And White-Collar Crime

    On Monday, the Criminal Division of the U.S. Department of Justice (DOJ) issued three new documents relevant to the Division's guidelines on self-reporting misconduct, whistleblowers, corporate compliance monitors, and enforcement priorities for investigating and prosecuting corporate crimes in the Trump Administration.
    United StatesCriminal Law
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    Treasury And Banking Regulators Propose Rules To Overhaul AML/CFT Supervision And Enforcement

    On April 7, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC) and National Credit Union Administration (NCUA) (collectively, the Banking Agencies)...
    United StatesFinance and Banking
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    Key Takeaways From The CFIUS Annual Report To Congress Covering Calendar Year 2025

    On August 7, 2026, the U.S. Department of the Treasury, as Chair of the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”), released its Annual Report to Congress covering calendar year 2025 (the “Report”). The Report provides detailed statistics on CFIUS filing volumes, review timelines, enforcement actions, and policy developments during 2025. Below, we summarize the key takeaways from the Report and their practical implications for M&A transactions. These statistics are increasingly important for dealmakers, as the CFIUS process can affect deal timing and risk allocation, and is critical to regulatory risk assessment across the M&A lifecycle.
    United StatesGovernment, Public Sector
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    SEC Charges Private Equity Adviser For Management Fee Offset Practices Inconsistent With Governing Documents

    On August 15, 2025, the SEC announced settled charges against a registered investment adviser to private equity funds (the "Adviser") for breaches of fiduciary duty...
    United StatesFinance and Banking
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    D.C. District Court Rules Against Google In Search Antitrust Case

    On August 5, 2024, Judge Amit Mehta of the United States District Court for the District of Columbia issued a decision in the landmark Google search case...
    United StatesAntitrust/Competition Law
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    December 31 Is Coming: Preparing For The CTA's Initial Reporting Deadline For Companies Formed Or Registered Prior To 2024

    The Corporate Transparency Act and its implementing regulations (collectively, the "CTA") became effective on January 1, 2024.
    United StatesCorporate/Commercial Law
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    Welsh Carson, FTC Resolve Administrative Complaint While New Chairman Signals A Shift In Views Concerning Private Equity Antitrust Enforcement

    On January 17, 2025, the last business day of the Biden administration, private equity firm Welsh, Carson, Anderson & Stowe and its affiliates ("Welsh Carson") reached a settlement with the Federal Trade Commission ("FTC").
    United StatesAntitrust/Competition Law
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    SEC Drops First Ever Liquidity Rule Suit Against Mutual Fund Adviser And Officers And Trustees

    On July 11, 2025, the SEC announced that it had filed a joint stipulation with Defendants Pinnacle Advisors, LLC ("Pinnacle"), two of Pinnacle's officers, and two mutual fund independent trustees to dismiss with prejudice the SEC's first-ever case seeking to enforce the Liquidity Rule.
    United StatesCorporate/Commercial Law
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    CARB Issues Proposed Regulations Implementing SB 253 And SB 261

    On December 9, CARB published proposed regulations to implement SB 253 (the Climate Corporate Data Accountability Act) and SB 261 (the Climate-Related Financial Risk Act) and a staff report outlining CARB's rationale for the regulations, …
    United StatesCorporate/Commercial Law
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    SEC Proposes Significant Amendments To Filer Status And Disclosure Requirements

    On May 19, 2026, the Securities and Exchange Commission released proposed amendments to the filer status framework for SEC reporting companies that would simplify reporting and disclosure requirements and reduce burdens on most reporting companies. The proposal is part of Chairman Paul Atkins’s “Make IPOs Great Again” agenda to incentivize companies to go and stay public.
    United StatesCorporate/Commercial Law
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    Looking Ahead To Extended Trading – SEC Approves Nasdaq's "23/5" Trading Proposal

    On April 10, 2026, the SEC approved a proposal[1] by The Nasdaq Stock Market (Nasdaq) to extend trading hours to 23 hours per day, five days per week, a significant expansion of Nasdaq's current trading hours.
    United StatesCorporate/Commercial Law
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP
  • Article

    Federal Reserve Proposes Long-Awaited Modernization Of Regulation O Insider Lending Rules

    On July 31, 2026, the Board of Governors of the Federal Reserve System (the “Board”) proposed the most significant updates to insider lending restrictions for banks in more than three decades (“Proposed Rule”). If finalized, the amendments to Regulation O would, among other things, modernize long-outdated dollar thresholds, codify significant staff interpretations and statutory provisions, and provide targeted relief for banks which have passive investment funds as “principal shareholders” (10% or more of a class of voting shares).
    United StatesCorporate/Commercial Law
    Simpson Thacher & Bartlett LLP
    Simpson Thacher & Bartlett LLP

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