Final Interagency Appraisal and Evaluation Guidelines (Part 2)

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...

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.

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.

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.

On May 29, 2026, the Commodity Futures Trading Commission (CFTC) took a series of coordinated actions to establish a domestic regulatory framework for perpetual contracts on digital commodities.

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement...

On 30 September 2021, the Ministry of Industry and Information Technology (MIIT) circulated for public comment the Measures on the Administration of Data Security in the Industry and Information Technology Sector

On December 18, 2025, President Trump signed into law the BIOSECURE Act as part of the National Defense Authorization Act (NDAA), which is the U.S. Congress's annual defense policy bill.

A recent proposal issued by Japan's ruling Liberal Democratic Party, along with various other current private- and public-sector initiatives, signals a strong interest in promoting investment in and the growth...

Japan is widely perceived as one of the least corrupt countries in the world. In 2020, Transparency International ranked Japan as the 19th least corrupt country out of 180 countries in...

On May 27, 2019, the Japanese government published amended rules[1] that aim to tighten the regulatory requirements applicable to foreign direct investment (tai nai chokusetsu toshi or FDI)

On June 30, 2017, the Wuhan Intermediate People's Court (the "Wuhan Court") issued a decision recognizing and enforcing a civil money judgment issued by the Los Angeles Superior Court arising out of...

The new Enterprise Bankruptcy Law of the People’s Republic of China (PRC) (Bankruptcy Law) was adopted on August 27, 2006 and will take effect on June 1, 2007, superseding the 1986-enacted Enterprise Bankruptcy Law (Trial) 1986, governing the bankruptcy of State-owned Enterprises . The Bankruptcy Law offers for the first time a unified regime applicable to all types of enterprises in China and also provides a more robust and detailed regime for enforcement of creditors’ claims. We discuss below

On 25 July 2018, the European Commission ("the Commission") published its decision on the Altice/PT Portugal gun jumping case. The Commission concluded that various contractual clauses allowed Altice N.V. ("Altice") ...

Like the COVID-19 virus, COVID-related contract claims have not gone away. In "Contracting in the Fog of War: Recovering Costs Caused by an Epidemic," we reported on Pernix Serka Joint Venture v. Department...