Publications & Learning

The Instructions Provide Details on How the Pilot Climate Scenario Analysis Exercise Will Be Conducted and the Information on Risk Management Practices That Will Be Gathered from Participants

Sullivan & Cromwell LLP - January 24, 2023

Assistant Attorney General Kenneth Polite Announces Additional Incentives for Companies to Voluntarily Disclose Misconduct, Cooperate, and Remediate

Sullivan & Cromwell LLP - January 19, 2023

IRS Notice Could Impact SPACs, Tax-Free Reorganizations, Intercompany Loans, and Accelerated Stock Repurchases

Sullivan & Cromwell LLP - January 10, 2023

Corporate Sustainability Reporting Directive Will Apply to Public and Private Companies, Including Many Non-EU Companies

Sullivan & Cromwell LLP - January 9, 2023

Sullivan & Cromwell LLP - January 6, 2023

Federal Reserve, FDIC, and OCC statement highlights crypto-asset risks to banking organizations

Sullivan & Cromwell LLP - January 4, 2023

SEC Staff Updates Guidance on Use of Non-GAAP Financial Measures

Sullivan & Cromwell LLP - December 19, 2022

FSB Endorses the IAIS Holistic Framework and Discontinues Annual Identification of Global Systemically Important Insurers

Sullivan & Cromwell LLP - December 15, 2022

Sullivan & Cromwell LLP - December 13, 2022

Recent Vote Outcomes, ISS & Glass Lewis Policy Updates and Other Developments

Sullivan & Cromwell LLP - December 7, 2022

Recent Legislative and Executive Action in the United States, Including the Infrastructure Investment and Jobs Act and the Inflation Reduction Act, Could Spur Growth of Clean Hydrogen as a Commercially Viable Way to Decarbonize the U.S. Economy

Sullivan & Cromwell LLP - November 22, 2022

SEC Action Imposes Substantial Additional Reporting Obligations

Sullivan & Cromwell LLP - November 21, 2022

Sullivan & Cromwell LLP - November 17, 2022

Agency Proposes Comprehensive Updates to Cybersecurity Protections Covered Entities Are Required to Implement

Sullivan & Cromwell LLP - November 14, 2022

Amendments Modify the Disclosure Framework for Mutual Funds and Exchange-Traded Funds to Create a New Layered Disclosure Approach to Highlight Key Information for Retail Investors

Sullivan & Cromwell LLP - November 7, 2022

NAFTA’s “Sunset Period” for Private Investors to Pursue Claims in Arbitration Will end as of July 1, 2023

Sullivan & Cromwell LLP - November 2, 2022

Court Vacates CFPB’s 2017 Payday Lending Rule, Finding That CFPB’s Funding Mechanism Violates the Separation of Powers Embodied in the Constitution’s Appropriations Clause

Sullivan & Cromwell LLP - October 28, 2022

Sullivan & Cromwell LLP - October 27, 2022

New Supervisory Framework Applies to Depository Institution Holding Companies Significantly Engaged in Insurance Activities

Sullivan & Cromwell LLP - October 17, 2022

Interested Parties Have Additional Time to Submit or Resubmit Comments on Proposed Rulemakings on Climate, Cybersecurity, Share Repurchases, SPACs, Investment Advisers, Investment Companies and Money Market Fund Reforms

Sullivan & Cromwell LLP - October 10, 2022

President Biden Provides Formal Direction to CFIUS on Supply Chains, Investment Trends, and Other Risk Factors

Sullivan & Cromwell LLP - September 20, 2022

Court Classifies Cybersecurity Risk as a Business Risk for SolarWinds; Oversight of Business Risk, Even if “Mission Critical,” Analyzed Under Business Judgment Rule, Not Caremark Standard

Sullivan & Cromwell LLP - September 19, 2022

Requires Disclosure of the Relationship Between Executive Compensation Actually Paid Versus Total Shareholder Return, Net Income and a Company Selected Measure; Effective for the 2023 Proxy Season for Calendar-Year Companies

Sullivan & Cromwell LLP - September 1, 2022

Sullivan & Cromwell LLP - August 22, 2022

Final Guidelines Provide Risk-Based Principles and a Three-Tiered Framework for Evaluating Institutions for Access to Federal Reserve Bank Accounts or Services

Sullivan & Cromwell LLP - August 19, 2022

The Act Modifies and Expands Tax Credits for Renewable Energy Production, Clean Energy Investments and Use of Alternative Power and Fuel Sources, and it Provides Significant Funding for a Wide Variety of Programs Relating to Climate Change

Sullivan & Cromwell LLP - August 17, 2022

The Inflation Reduction Act Will Impose a One Percent Tax on Stock Repurchases, With Unique Implications for Banking Organizations

Sullivan & Cromwell LLP - August 15, 2022

The Secondary Capital Raising Review Has Delivered 21 Recommendations to Improve Secondary Capital Raisings in the UK and Provides a “Once-in-a-Generation” Opportunity for Meaningful Reform.

Sullivan & Cromwell LLP - August 10, 2022

The Proposed Act Includes a New Corporate Alternate Minimum Tax and Carried Interest Rules Changes Similar to the Past Versions of the Proposed 2021 Build Back Better Bill

Sullivan & Cromwell LLP - August 2, 2022

Proposed Amendments Would Significantly Narrow Standards for Exclusion on the Bases of Substantial Implementation, Duplication and Resubmission

Sullivan & Cromwell LLP - July 21, 2022

FCA Reminds Issuers of Rules Applicable to ESG-labelled Bond Issuances, Endorses ICMA Principles and Guidelines and Anticipates Regulation of ESG Data and Rating Providers

Sullivan & Cromwell LLP - July 13, 2022

October Term 2021

Sullivan & Cromwell LLP - July 7, 2022

Decision Allows Employees and Employers to Agree to Arbitration of Individual PAGA Claims, Which Generally Will Preclude “Representative” PAGA Claims on Behalf of Others

Sullivan & Cromwell LLP - June 21, 2022

The Request for Comment Focuses on Whether Activities of Index Providers, Model Portfolio Providers and Pricing Services May Cause Them to be Within the Definition of “Investment Adviser”

Sullivan & Cromwell LLP - June 21, 2022

U.S. Supreme Court Rules That 28 U.S.C. § 1782 Does Not Authorize Discovery in Aid of an International Commercial Arbitration or an Ad Hoc Investor-State Arbitration

Sullivan & Cromwell LLP - June 17, 2022

Amendments Mandate the Electronic Filing or Submission Through EDGAR of Certain Documents that are Currently Permitted to be Filed in Paper Form

Sullivan & Cromwell LLP - June 8, 2022

Proposed Amendments Would Expand Existing Requirements to ESG Funds and Certain Other Funds, and Increase Disclosure and Other Obligations of Funds Subject to the Rule

Sullivan & Cromwell LLP - June 3, 2022

Upcoming Amendments to the UK Merger Control Thresholds and the Commencement of the UK FDI Regime

Sullivan & Cromwell LLP - May 31, 2022

General Court Upholds EUR 28 Million Gun-Jumping Fine for Canon’s Two-Step “Warehousing” Acquisition of Toshiba Medical Systems

Sullivan & Cromwell LLP - 24 May 2022

Proposal Seeks to Modernize CRA Regulations and Standardize Their Application Across the Agencies

Sullivan & Cromwell LLP - May 23, 2022

The Supreme Court Agrees to Take a Case Concerning the Constitutionality of SEC Administrative Law Judges and the Fifth Circuit Invalidates Aspects of SEC Administrative Proceedings

Sullivan & Cromwell LLP - May 20, 2022

Amendments of Particular Significance for Bidders

Sullivan & Cromwell LLP - May 17, 2022

SEC Division of Corporation Finance Publishes Sample Comment Letter Regarding Disclosures Pertaining to Russia’s Invasion of Ukraine and Related Supply Chain Issues

Sullivan & Cromwell LLP - May 9, 2022

CFPB Also Seeks Comment on Update to Related Procedures

Sullivan & Cromwell LLP - April 29, 2022

Changes to U.K. Listing Rules and Disclosure Guidance and Transparency Rules

Sullivan & Cromwell LLP - April 27, 2022

NYDFS Circular Letter Provides Guidance on Potential Control Issues in Transactions With New York Domiciled Insurers

Sullivan & Cromwell LLP - April 25, 2022

Complaint Alleges Violations of 2017 Consent Order and Various Consumer Protection Laws and Reflects CFPB Director Chopra’s Focus on “Recidivist” Companies, Executive Accountability, and Alleged Credit Reporting Agency Misconduct

Sullivan & Cromwell LLP - April 13, 2022

Proposed Climate Rules Would Subject Foreign Private Issuers to Substantially Similar Obligations as U.S. Companies and Require New Disclosures from Companies Currently Reporting Under Home Jurisdiction Rules

Sullivan & Cromwell LLP - April 6, 2022

California Board Diversity Law Invalidated, but Focus on Board Diversity Remains

Sullivan & Cromwell LLP - April 5, 2022

Would Mandate Specific Disclosures, Expand Underwriter Liability to De-SPAC Transactions, Eliminate the PSLRA Safe Harbor for De-SPAC Projections and Seek to Clarify Treatment of SPACs Under the Investment Company Act of 1940

Sullivan & Cromwell LLP - March 31, 2022

Would Require Public Companies to Disclose Detailed Greenhouse Gas Emissions, Climate Transition Plans, Targets and Progress Against Targets, Long-Term Climate Risks and Business Impacts, and Climate-Related Corporate Governance, Including New Information in Notes to Audited Financial Statements

Sullivan & Cromwell LLP - March 28, 2022

Changes Broaden Analysis of Unfair Acts or Practices to Embrace Discriminatory Conduct and Signal Agency’s Continued Focus on Fair Lending Issues, Including in Algorithms

Sullivan & Cromwell LLP - March 25, 2022

The United States, the United Kingdom, and the European Union Impose Additional Sanctions Responding to Russia’s Invasion of Ukraine

Sullivan & Cromwell LLP - March 23, 2022

“Adjustable Interest Rate (LIBOR) Act” Is Enacted to Provide a Uniform, National Solution for “Tough Legacy” Contracts

Sullivan & Cromwell LLP - March 17, 2022

Statutory Deadline for Decision Begins to Run When a Notice With Basic Information Is Submitted

Sullivan & Cromwell LLP - March 14, 2022

Options Under Consideration Include a Nondiscrimination Quality Control Factor; Focus on Algorithmic Bias Not Limited to Automated Valuation Models

Sullivan & Cromwell LLP - March 10, 2022

The Order Aims to Align the U.S. Government’s Approach to Digital Asset Regulation and Requests Assessment of U.S. Central Bank Digital Currency

Sullivan & Cromwell LLP - March 9, 2022

U.K. Government Proposes Most Significant Changes in a Generation

Sullivan & Cromwell LLP - March 7, 2022

Department of Justice Creates Task Force to Hold Accountable Corrupt Russian Oligarchs

Sullivan & Cromwell LLP - March 3, 2022

The United States, United Kingdom and European Union Institute Wide-Reaching Sanctions Responding to Russia’s Invasion of Ukraine

Sullivan & Cromwell LLP - February 28, 2022

Treasury Releases a Study on the Facilitation of Money Laundering and the Financing of Terrorism Through the Trade in Works of High-Value Art

Sullivan & Cromwell LLP - February 22, 2022

Proposal Would Impose Substantial New Disclosure Obligations and Prohibitions on a Broad Range of Activities

Sullivan & Cromwell LLP - February 16, 2022

Sullivan & Cromwell LLP - February 14, 2022

The “Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act” Prohibits Mandatory Arbitration of Disputes, Including Class and Collective Actions, Involving Sexual Assault and Sexual Harassment Claims

Sullivan & Cromwell LLP - February 10, 2022

Proposed Amendments to Form PF Are Aimed at Enhancing FSOC’s Ability to Assess Systemic Risk and Improving the SEC’s Oversight of Private Fund Advisers and Investor Protection Efforts

Sullivan & Cromwell LLP - February 1, 2022

“Misalignment of Interests” Between Sponsor and Stockholders a Source of Legal Risk for Directors of SPACs

Sullivan & Cromwell LLP - January 26, 2022

Revised Jurisdictional Thresholds

Sullivan & Cromwell LLP - January 24, 2022

FTC and DOJ Launch a Joint Review of Guidelines for Both Horizontal and Vertical Mergers, Issuing a Request for Public Comment

Sullivan & Cromwell LLP - January 19, 2022

New York Supreme Court Dismisses Two Derivative Suits Brought Against Directors and Officers of Bayer AG and UBS Group AG for Alleged Breaches of Fiduciary Duty, Finding That Those Actions Must Be Brought in the Companies’ Home Forums.

Sullivan & Cromwell LLP - January 6, 2022

Sullivan & Cromwell LLP - December 21, 2021

Proposed Amendments to Certain Rules Under the Investment Company Act That Govern Money Market Funds are Aimed at Improving Their Resilience and Transparency

Sullivan & Cromwell LLP - December 21, 2021

Federal Trade Commission Strengthens Information Security Safeguards for Consumer Financial Information

Sullivan & Cromwell LLP - December 20, 2021

UK Financial Conduct Authority Publishes Final Changes to the UK Listing Rules for Companies Listed on the London Stock Exchange Following Its Primary Market Effectiveness Review

Sullivan & Cromwell LLP - December 17, 2021

CMA Moves Against Big Tech With Decision to Unwind Facebook’s Acquisition of GIPHY

Sullivan & Cromwell LLP - December 7, 2021

Final Guidance Requires Insurers to Integrate Consideration of Climate Risks into Governance, Operations, Risk Management, Scenario Analysis and Disclosure

Sullivan & Cromwell LLP - November 30, 2021

Federal Reserve, FDIC and OCC Provide Update Regarding Crypto-Asset Regulation, Including Proposed Regulatory Roadmap for 2022

Sullivan & Cromwell LLP - November 24, 2021

Final Rule Requires Banking Organizations to Notify Primary Federal Regulator of Certain Cyber Incidents Within 36 Hours, and Bank Service Providers to Notify Banking Organization Customers as Soon as Possible

Sullivan & Cromwell LLP - November 22, 2021

SCOTUS Denies Cert in Challenge to SEC’s Suspicious Activity Reporting Regime

Sullivan & Cromwell LLP - November 15, 2021

Rescinds Previous Guidance, Enabling More Shareholder Proposals on Environmental and Social Issues; Also Facilitates Use of Graphics and Email

Sullivan & Cromwell LLP - November 8, 2021

FSOC Identifies Climate Change as an Emerging Threat to U.S. Financial Stability and Recommends Accelerated and Coordinated Actions by U.S. Financial Regulators to Enhance the Resiliency of the Financial System to Climate-Related Risks

Sullivan & Cromwell LLP - November 2, 2021

Deputy Attorney General Lisa Monaco Announces Revisions to Justice Department Policy in Prosecuting and Resolving Corporate Investigations

Sullivan & Cromwell LLP - October 29, 2021

Attorney General Garland Sets Expectation for Increase in “Redlining” Investigations and Enforcement

Sullivan & Cromwell LLP - October 25, 2021

Original Proposal in 2015 Would Require Clawback of Excess Incentive-Based Compensation Earned by Executive Officers During the Three Fiscal Years Preceding an Accounting Restatement to Correct for Material Error; SEC Specifically Seeks Comment and Data on Ten Potential Changes to the Original Proposal

Sullivan & Cromwell LLP - October 18, 2021

The OECD/G20 Inclusive Framework Reached a New Global Agreement on Profit Allocation and Minimum Tax

Sullivan & Cromwell LLP - October 12, 2021

New California Law Expands Prohibition of Settlement NDAs

Sullivan & Cromwell LLP - October 11, 2021

Proposal Shows SEC’s Focus on ESG Matters; Would Also Complete the SEC’s Rulemaking Under Section 951 of the Dodd-Frank Act

Sullivan & Cromwell LLP - October 5, 2021

A Reminder About the Need to Monitor Officer and Director Stock Compensation and Other Acquisitions for Potential HSR Filing Requirements

Sullivan & Cromwell LLP - September 30, 2021

New Guidance Incentivizes Reporting, Defensive Cybersecurity Measures for Companies Facing Ransomware Attacks

Sullivan & Cromwell LLP - September 23, 2021

Mega-Cap and Large-Cap Consumer Companies Vary in Adoption of Corporate Governance Practices

Sullivan & Cromwell LLP - September 22, 2021

House Ways and Means Committee Chairman Richard Neal Released the Committee’s Budget Proposal That Includes a Variety of Changes to Federal Estate, Gift and Trust Taxation

Sullivan & Cromwell LLP - September 16, 2021

Federal Reserve Publishes Additional Guide for Community Banks

Sullivan & Cromwell LLP - September 15, 2021

SEC Chair Gary Gensler’s Remarks Before ABA Committee Remind Market Participants of Upcoming Regulatory Changes for Security-Based Swap Dealers and Major Security-Based Swap Participants

Sullivan & Cromwell LLP - September 14, 2021

CFPB Proposed Rule Would Implement Dodd-Frank Small Business Lending Data Collection Requirements

Sullivan & Cromwell LLP - September 10, 2021

Investor Advisory Subcommittees Publish Draft Recommendations Addressing SPAC Disclosure Concerns; Recommend Further SEC Analysis

Sullivan & Cromwell LLP - September 8, 2021

Actions Illustrate SEC’s Heightened Focus on Cybersecurity Controls and Disclosure Controls and Procedures in the Cybersecurity Context

Sullivan & Cromwell LLP - September 1, 2021

NYSE Adds Back $120,000 Threshold to Related Party Transaction Requirements

Sullivan & Cromwell LLP - August 31, 2021

Sullivan & Cromwell LLP - August 23, 2021

Recent CFTC Statements and Recommendations Emphasize the Importance of the Transition Away From LIBOR

Sullivan & Cromwell LLP - August 16, 2021

UK Financial Conduct Authority to Amend the UK Listing Regime to Enhance the Attractiveness of London as a Potential Listing Venue for SPACs

Sullivan & Cromwell LLP - July 30, 2021

Shareholders Submit 733 Proposals for Meetings in the First Half of 2021, the Highest Number Since S&C Began Tracking Submissions

Sullivan & Cromwell LLP - July 27, 2021

The Order Directs a Host of Federal Agencies to Take a More Interventionist Role in Regulating Competition and Preventing “Unfair” Business Practices; Major Agency Rulemakings and Policy Changes are Anticipated That Will Lead to Increased Scrutiny of M&A Activity and Business Practices in Many Industries, Including Banking, Technology, Tlecommunications, Transportation, and Healthcare

Sullivan & Cromwell LLP - July 12, 2021

Agency Recommends Preventative Measures Amid Growing Regulatory Focus on the Ransomware Threat

Sullivan & Cromwell LLP - July 2, 2021

FDIC Publishes New Guidance Streamlining Resolution Planning for Specified IDIs

Sullivan & Cromwell LLP - June 29, 2021

Largest Shareholder Did not Owe Fiduciary Duties Absent Domination Over Independent Special Committee’s Merger Negotiations

Sullivan & Cromwell LLP - June 21, 2021

Sullivan & Cromwell LLP - June 17, 2021

New Executive Orders Modify Restrictions on Purchases of Securities of “Chinese Military-Industrial Complex Companies,” and Direct New Measures to Protect U.S. Personal Data; China Enacts New Anti-Foreign Sanctions Law

Sullivan & Cromwell LLP - June 15, 2021

Sullivan & Cromwell LLP - June 2021

Court Holds That the Computer Fraud and Abuse Act Does not Apply to an Individual who Is Authorized to Access Information on a Computer but Does so for an Improper Purpose

Sullivan & Cromwell LLP - June 4, 2021

COVID-19 Effects Did Not Qualify as Material Adverse Effect; Provision Limiting Specific Performance Knocked Out by Prevention Doctrine

Sullivan & Cromwell LLP - May 21, 2021

Sweeping Order Aims to Improve and Modernize the United States’ Cybersecurity Defenses in Partnership With the Private Sector

Sullivan & Cromwell LLP - May 14, 2021

Issuers Should Review Structured Instruments to Identify any Mismatch in Payments Arising From Differing State Laws

Sullivan & Cromwell LLP - May 3, 2021

Report Characterizes Attack as a “Wake-up” Call, Recommends Cybersecurity Measures for Financial Services Industry

Sullivan & Cromwell LLP - April 29, 2021

The Ruling Could Significantly Impact the FTC’s Enforcement Program

Sullivan & Cromwell LLP - April 22, 2021

EU Parliament Proposes Mandatory Due Diligence and Corporate Accountability Legislation; EU Also Establishes Global Human Rights Sanctions Regime; European Countries and Courts Take Other Steps on Corporate ESG Accountability

Sullivan & Cromwell LLP - April 8, 2021

Poison Pill Provision Insufficient to Survive Unocal Scrutiny if Perceived Threat Is Only Hypothetical and the Provision is so Broad as to Abrogate Potentially Innocuous Exercise of Shareholder Rights

Sullivan & Cromwell LLP - April 6, 2021

DFS Announces New Actions to Promote Diversity, Equity and Inclusion in the Insurance Industry

Sullivan & Cromwell LLP - April 1, 2021

Detailed Guidance Would Establish Expectation That Insurers Integrate Consideration of Climate Risks Into Governance, Operations, Risk Management, Scenario Analysis and Disclosure

Sullivan & Cromwell LLP - March 31, 2021

European Commission Extends Jurisdiction to Non-Reportable Transactions

Sullivan & Cromwell LLP - March 31, 2021

Sullivan & Cromwell LLP - March 19, 2021

FinCEN Informs Financial Institutions of New AML Measures to Combat the Illegal Trade in Antiquities and Art

Sullivan & Cromwell LLP - March 18, 2021

Virginia Is the Second State to Enact Comprehensive Privacy Legislation in the U.S.

Sullivan & Cromwell LLP - March 11, 2021

The U.K. Government has Published a Wide-Ranging Review of the U.K. Listing Regime. The Review Recommends a Number of Material Reforms to the U.K.’s Listing Regime to Facilitate Capital-Raising on the London Market with a View to Enhancing the Attractiveness of London as a Potential Listing Venue, in Particular for Growth Companies and SPACs

Sullivan & Cromwell LLP - March 3, 2021

Sullivan & Cromwell LLP - February 17, 2021

The DFS Issues Guidance to Insurers on Best Practices to Manage Their Cyber Insurance Risk

Sullivan & Cromwell LLP - February 12, 2021

Disclosure Trends and Form Considerations for Issuers Preparing Filings for Fiscal Year 2020

Sullivan & Cromwell LLP - February 9, 2021

FinCEN Developments in 2020 Signal Coming Changes to the AML Regime, Continue to Alert Financial Institutions to Evolving Threats, and Emphasize Individual Accountability for AML Failures

Sullivan & Cromwell LLP - February 8, 2021

Revised Jurisdictional Thresholds

Sullivan & Cromwell LLP - February 2, 2021

CFTC Issues Letter Authorizing the NFA’s Review Process for Approving Swap Dealer Internal Models

Sullivan & Cromwell LLP - January 22, 2021

Novel, Non-SEP Patent Pool Formed by 15 Leading Research Universities, Advised by Sullivan & Cromwell, Receives Favorable Business Review from DOJ

Sullivan & Cromwell LLP - January 15, 2021

Stakeholder Interest in Contribution and Lobbying Policies Has Been Increasing for Years, but Recent Events Have Caused Companies to Rapidly Re-Examine Approaches to Political Giving

Sullivan & Cromwell LLP - January 13, 2021

Latest Stimulus Legislation Provides Additional Coronavirus Relief

Sullivan & Cromwell LLP - January 5, 2021

The Consolidated Appropriations Act, 2021 Includes Provisions Extending COVID-19-Related Unemployment Benefits and Certain Tax Incentives for Employers

Sullivan & Cromwell LLP - December 31, 2020

FDIC Adopts Final Rule Requiring Certain Conditions and Commitments for Insured Industrial Banks or Industrial Loan Companies With Parents That are not Subject to Regulation by the Federal Reserve Board

Sullivan & Cromwell LLP - December 29, 2020

Sullivan & Cromwell LLP - December 28, 2020

The Court of Appeal Sanctioned the Scheme and Reversed the Lower Court’s Decision

Sullivan & Cromwell LLP - December 23, 2020

Review of CFTC Final Rule Covering Cross-Border Swaps Registration Thresholds, ANE Transactions, and Substituted Compliance

Sullivan & Cromwell LLP - December 22, 2020

Proposal Would Require Banking Organizations to Notify Primary Federal Regulator of Significant Incidents Within 36 Hours; Bank Service Providers to Notify Any Affected Bank Immediately

Sullivan & Cromwell LLP - December 22, 2020

DPC Finds Twitter’s Irish Subsidiary Had Constructive Knowledge of a Personal Data Breach Through its Processor, and Thus Failed to Notify in a Timely Manner and to Adequately Document the Breach

Sullivan & Cromwell LLP - December 21, 2020

Regulating Big Tech: The Draft EU Platform and Online Content Legislation Reveals an Ambitious Plan

Sullivan & Cromwell LLP - December 20, 2020

New Legislation to Implement Comprehensive Modernization and Reform of the US AML/CFT Regime

Sullivan & Cromwell LLP - December 17, 2020

CFTC Adopts Final Rule on Electronic Trading Risk Principles

Sullivan & Cromwell LLP - December 16, 2020

New Rule 2a-5 Under the Investment Company Act of 1940 Establishes Requirements for the Determination of Fair Value for Fund Investments, Codifies the Ability of Fund Boards to Designate a Valuation Designee to Perform Fair Valuation Determinations, and Rescinds Certain Existing Guidance

Sullivan & Cromwell LLP - December 14, 2020

COVID-19 Effects Do Not Qualify as Material Adverse Effect; Buyer May, However, Terminate For Breach of Interim Operating Covenants

Sullivan & Cromwell LLP - December 4, 2020

Proposed Temporary Rules Would Permit Corporations, for Five Years, to Use Rule 701 and Form S-8 to Compensate and Make Registered Securities Offerings to Certain Platform Workers and Also Proposes to Simplify and Modernize the Framework for Compensatory Offerings

Sullivan & Cromwell LLP - December 3, 2020

LIBOR Benchmark Administrator Proposes Extending Publication of Widely Used USD LIBOR Settings to June 30, 2023; Federal Banking Agencies Issue Guidance that Banks Should Generally Cease Entering Into New Contracts Referencing USD LIBOR by End of 2021, and Observes the Extended Date Will Facilitate the Roll-Off of Legacy Contracts

Sullivan & Cromwell LLP - December 1, 2020

Amendments to Regulation S-K Modernize, Simplify and Enhance MD&A and Other Financial Disclosures

Sullivan & Cromwell LLP - November 23, 2020

Charges Against Five Firms Highlight Division of Enforcement’s Initiative Concerning Risks of Complex Exchange-Traded Products

Sullivan & Cromwell LLP - November 17, 2020

UK Government Strengthens Powers to Intervene in Direct and Indirect Acquisitions of UK Companies, Assets and IP on National Security Grounds

Sullivan & Cromwell LLP - November 12, 2020

Advisory Highlights Risks Relating to the Involvement of “Blocked Persons” in Transactions in the High-Value Art Market

Sullivan & Cromwell LLP - November 5, 2020

Sullivan & Cromwell LLP - November 3, 2020

Adjustments to annual incentive programs such as changes to metrics, performance targets or measurement periods or replacement with one-time discretionary payments may be viewed as reasonable responses
Particular scrutiny on above target payouts under modified annual incentive programs and changes to currently in-progress equity or long-term incentive cycles

Sullivan & Cromwell LLP - October 21, 2020

Final Rule Establishes Rules-Based Regime to Permit Funds to Acquire Shares of Other Funds in Excess of Limits in Section 12(d)(1) of the Investment Company Act

Sullivan & Cromwell LLP - October 19, 2020

DOJ Calls for Increased Interagency and International Cooperation in Enforcing Virtual Currency Regulations.

Sullivan & Cromwell LLP - October 12, 2020

New Minimum Requirements Build Upon Existing Law Mandating Female Representation

Sullivan & Cromwell LLP - October 1, 2020

Federal Reserve Issues Frequently Asked Questions Relating to the Final Rule Revising the “Controlling Influence” Prong of the Federal Reserve’s Control Rules

Sullivan & Cromwell LLP - September 30, 2020

New Rule Finalizes More Stringent Minimum Shareholding and Resubmission Requirements for Shareholder Proposals and Will Be Effective for 2022 Proxy Season

Sullivan & Cromwell LLP - September 30, 2020

Hydrogen Series – Part 2

Sullivan & Cromwell LLP - September 28, 2020

Final Rules Continue the SEC’s Efforts to Eliminate Disclosure Requirements That Overlap With Other SEC Rules and Accounting Standards by Replacing Industry Guide 3 With Updated Disclosure Rules in a New Subpart of Regulation S-K

Sullivan & Cromwell LLP - September 25, 2020

Hydrogen Series – Part 1

Sullivan & Cromwell LLP - September 23, 2020

Prohibitions on Transactions Related to TikTok Delayed Until September 27 Following President’s Approval of Transaction with Oracle and Walmart; Prohibitions on Transactions Related to WeChat Delayed Temporarily Following United States District Court’s Preliminary Injunction

Sullivan & Cromwell LLP - September 21, 2020

Update to 2015 Business Review Letter to IEEE Provides Further Evidence That the Antitrust Division Seeks to Have Market Forces—Rather Than Pre-Set Rules—Impact the Terms of Licenses for Standard Essential Patents

Sullivan & Cromwell LLP - September 11, 2020

The Updated EEOC Guidance Provides Further Clarity for Employers Concerning the ADA and COVID-19

Sullivan & Cromwell LLP - June 4, 2021

The Los Angeles County Superior Court’s Decision Calls into Question Continued Enforceability by California Courts in Actions at Law of Provisions That Designate Forums Without Trials by Jury

Sullivan & Cromwell LLP - September 4, 2020

Amendments Make Disclosures of Business and Risk Factors More Principles-Based, Add a New Human Capital Disclosure Requirement and Update Certain Requirements for Disclosure of Legal Proceedings

Sullivan & Cromwell LLP - August 31, 2020

Decision Establishes Authority of UK Courts to Set Global FRAND License Terms and Provides Other Important Guidance to SEP Owners and Implementers

Sullivan & Cromwell LLP - August 27, 2020

NYMEX and Two Ex-Staffers to Pay $4M Fine in CFTC Settlement

Sullivan & Cromwell LLP - August 14, 2020

Sullivan & Cromwell LLP - August 12, 2020

Final Regulations Adopt 2018 Proposed Regulations With Key Modifications

Sullivan & Cromwell LLP - August 6, 2020

Changes Clarify and Update Rules Governing the Protection and Disclosure of CSI and Other Nonpublic Information

Sullivan & Cromwell LLP - August 5, 2020

Action Against Title Insurance Company Based on Asserted Failure to Protect Tens of Millions of Documents Containing Sensitive Consumer Information

Sullivan & Cromwell LLP - July 31, 2020

Proxy Advisors Required to Provide Notice of Company Responses to Recommendations and Comprehensive Disclosure of Conflicts of Interest

Sullivan & Cromwell LLP - July 28, 2020

U.S. Government Takes Civil and Criminal Enforcement Actions Against Non-U.S. Company for Violation of North Korea Sanctions Based on Use of U.S. Financial System

Sullivan & Cromwell LLP - July 24, 2020

OCC Interpretive Letter Confirms National Bank Authority to Provide Cryptocurrency Custody Services

Sullivan & Cromwell LLP - July 23, 2020

Sullivan & Cromwell LLP - July 22, 2020

FDIC Requests Information and Comment Relating to the Potential Establishment of a Standards-Based Voluntary Certification Framework to Facilitate Banks’ Use of Financial Technology

Sullivan & Cromwell LLP - July 22, 2020

October Term 2019

Sullivan & Cromwell LLP - July 17, 2020

Proposal Would Increase the Form 13F Reporting Threshold From $100 Million to $3.5 Billion and Make Other Rule and Form Amendments

Sullivan & Cromwell LLP - July 15, 2020

U.S. Congress Passes Sanctions Bill in Response to Chinese National Security Law

Sullivan & Cromwell LLP - July 7, 2020

Vertical Merger Guidelines Issued Outlining Considerations Relevant to Application of the Antitrust Laws to Transactions Combining Assets At Different Levels of a Supply Chain

Sullivan & Cromwell LLP - July 2, 2020

Sullivan & Cromwell LLP - July 1, 2020

Considerations for U.S. Public Company Directors

Sullivan & Cromwell LLP - June 29, 2020

The U.S. Supreme Court Declines Review of Ninth Circuit Opinion Holding that Stock-Based Compensation Costs Must be Shared under Qualified Cost Sharing Agreements

Sullivan & Cromwell LLP - June 29, 2020

CFTC Releases New Proposed Rule on Electronic Trading Risk Principles and Withdraws Regulation AT Proposal

Sullivan & Cromwell LLP - June 26, 2020

Sullivan & Cromwell LLP - June 26, 2020

Division of Corporation Finance Provides Additional Disclosure Guidance for Reporting on the Impact of COVID-19 and the Office of the Chief Accountant Issues Statement on the Importance of High-Quality Financial Reporting in Light of COVID-19

Sullivan & Cromwell LLP - June 25, 2020

European Commission’s Broad-Brush “Four-To-Three Is Bad” Approach Taken Down By General Court In Three-O2 Judgment

Sullivan & Cromwell LLP - June 18, 2020

The Updated EEOC Guidance Addresses Best Practices for Employers to Determine if Employees Need an Accommodation

Sullivan & Cromwell LLP - June 12, 2020

Recent Developments Regarding Frameworks Developed by the Sustainability Accounting Standards Board, the Task Force on Climate-Related Financial Disclosures and Other Standard-Makers

Sullivan & Cromwell LLP - June 8, 2020

U.K. Government Updates Terms of Covid Corporate Financing Facility

Sullivan & Cromwell LLP - June 5, 2020

DOJ Criminal Division Provides More Detailed Guidance for Assessing Compliance Programs by Updating and Elaborating on a Prior Policy Document

Sullivan & Cromwell LLP - June 3, 2020

SEC Adopts Amendments to Update Significance Tests, Expand Use of Pro Forma Financial Information in Measuring Significance and Amend the Pro Forma Financial Information Requirements With Respect to Presenting Adjustments

Sullivan & Cromwell LLP - May 29, 2020

Federal Reserve, FDIC, NCUA and OCC Issue Interagency Lending Principles for Offering Responsible Small-Dollar Loans

Sullivan & Cromwell LLP - May 28, 2020

Sullivan & Cromwell LLP - May 21, 2020

The U.S. Supreme Court Reaffirms that, to Be Punishable as Wire or Federal-Program Fraud, the Core Purpose of a Fraudulent Scheme Must Be to Obtain Money or Property.

Sullivan & Cromwell LLP - May 12, 2020

Sullivan & Cromwell LLP - May 11, 2020

Proposed Legislation Would Prevent Mergers and Acquisitions by Most Companies and Investment Funds During the COVID-19 Pandemic

Sullivan & Cromwell LLP - May 1, 2020

EU Taxonomy, Updated Equator Principles, New Actions by Securities Regulators and Other Recent Developments

Sullivan & Cromwell LLP - April 30, 2020

SEC Adopts Amendments to the Registration, Offering and Communications Processes and Other Aspects of the Disclosure and Regulatory Framework for Business Development Companies and Registered Closed-End Funds to Provide Parity with Operating Companies

Sullivan & Cromwell LLP - April 27, 2020

Sullivan & Cromwell LLP - April 23, 2020

Court Will Review Whether the Computer Fraud and Abuse Act Prohibits an Individual Who Is Authorized to Access Information on a Computer for Specific Purposes from Accessing that Information for an Improper Purpose

Sullivan & Cromwell LLP - April 21, 2020

Court Holds 35 U.S.C. § 314(d) Generally Precludes Appeals of PTO IPR Institution Decisions, Including Decisions Regarding Whether the IPR Is Time-Barred Under § 315(b)

Sullivan & Cromwell LLP - April 21, 2020

Court Dismisses Action Against lululemon Directors Based on Paying Severance to Former CEO Notwithstanding Ability to Terminate for “Cause”

Sullivan & Cromwell LLP - April 15, 2020

UK’s Financial Conduct Authority (FCA) Announces a Series of Temporary Measures Designed to Assist Issuers Raising Capital During the COVID-19 Pandemic

Sullivan & Cromwell LLP - April 15, 2020

Sullivan & Cromwell LLP - April 14, 2020

Bed Bath & Beyond Sues 1-800-Flowers for Refusing to Close; Hexcel and Woodward Agree to Terminate Merger of Equals – Adopt Limited Duration Rights Plans

Sullivan & Cromwell LLP - April 13, 2020

Federal Reserve Takes Additional Actions to Provide Up to $2.3 Trillion in Loans to Support Economy in Response to COVID-19

Sullivan & Cromwell LLP - April 13, 2020

Insurance Legislative and Regulatory Activity in Response to COVID-19—U.S. and EU Developments

Sullivan & Cromwell LLP - April 9, 2020

ISS Releases Guidance on Policies Regarding Virtual-Only Meetings, Compensation-Related Issues, Defensive Measures and Director Attendance Amid the COVID-19 Pandemic

Sullivan & Cromwell LLP - April 9, 2020

Updated Guidance Relaxes Notice and Access Timing Requirements When Delays Are Unavoidable

Sullivan & Cromwell LLP - April 9, 2020

COVID-19-Related Risk Factor and Other Disclosure Considerations for Banking Institutions’ First Quarter 2020 Form 10-Q Filings

Sullivan & Cromwell LLP - April 6, 2020

Practical Considerations to Address the Unique Challenges and Circumstances Created by COVID-19

Sullivan & Cromwell LLP - April 2, 2020

Coronavirus Aid, Relief, and Economic Security Act Offers More than $50 billion in Financial Assistance for Certain Aviation-Related Companies, Subject to Significant Restrictions on Capital Allocation, Employee Retention and Compensation and Other Conditions, Including the Issuance of Warrants or Other Instruments to the U.S. Government

Sullivan & Cromwell LLP - March 30, 2020

Companies Should Be Alert to Cybercriminals Exploiting Remote Working Vulnerabilities and Interest in COVID-19

Sullivan & Cromwell LLP - March 30, 2020

CARES Act Provides Tax Relief to Businesses

Sullivan & Cromwell LLP - March 30, 2020

Sweeping Stimulus Legislation Authorizes $500 Billion to Support Distressed Sectors of the Economy, Temporary Suspension or Modification of Certain Banking Provisions and Nearly $350 Billion to Support Small Businesses Through a Temporary Paycheck Protection Program in Response to the Coronavirus Outbreak

Sullivan & Cromwell LLP - March 29, 2020

Court Endorses the Application of Howey to Digital Assets and ICOs and Issues Injunction Barring Distribution of Telegram’s Grams

Sullivan & Cromwell LLP - March 27, 2020

CFTC Issues Guidance on What Constitutes the “Actual Delivery” of Virtual Currencies in the Context of Retail Commodity Transactions

Sullivan & Cromwell LLP - March 26, 2020

Regulator Outlines Adjustments Designed to Assist Financial Institutions in Deploying Resources While Continuing to Support Customers and Local Economies; Confirms No Delay in April 6 CCAR Capital Plan Submission Deadline

Sullivan & Cromwell LLP - March 25, 2020

California Business, Consumer Services and Housing Agency and California Department of Business Oversight Issue Guidance to Financial Institutions During the COVID-19 Pandemic

Sullivan & Cromwell LLP - March 25, 2020

Latest Action Follows a Series of Recent Steps Taken by the Agency to Provide Assistance and Relief to Funds and Investment Advisers in Response to Coronavirus

Sullivan & Cromwell LLP - March 24, 2020

Regulator Authorizes Action by the Enterprises in Light of the COVID 19 National Emergency

Sullivan & Cromwell LLP - March 24, 2020

Regulators Issue Statement on Loan Modifications and Reporting for Financial Institutions Working with Customers Affected by COVID-19

Sullivan & Cromwell LLP - March 22, 2020

Charter Mandating That Federal Securities Act Claims Be Filed in Federal Courts Held to Be Permissible Under Section 102(b)(1) of the Delaware General Corporation Law and Thus Facially Valid

Sullivan & Cromwell LLP - March 20, 2020

Disclosure Considerations for U.S. Public Companies

Sullivan & Cromwell LLP - March 20, 2020

For Private Employers with Fewer than 500 Employees and Public Agencies, This Emergency Act Expands the Family and Medical Leave Act of 1993 and Enacts an Emergency Paid Sick Leave Act. The Legislation Provides for Certain Payroll Tax Credits to Cover Wages Paid Under These Programs and Certain Qualified Health Plan Expenses

Sullivan & Cromwell LLP - March 19, 2020

Individuals and Corporations Can Postpone Certain Income Tax Payments (up to a Cap) Until July 15, 2020; the Due Date to File Tax Returns Has Not Changed (Yet)

Sullivan & Cromwell LLP - March 19, 2020

Thematic Specialty Voting Policy Intended to Respond to Growing Investor Focus on Climate Risk and Includes Potential Recommendations Against Directors for Failure to Adequately Address Climate-Related Risks and, Under Extraordinary Circumstances, for Other ESG Failures (Including Director Actions on Other Boards)

Sullivan & Cromwell LLP - March 19, 2020

Legal Considerations in Light of COVID-19 and New SEC Guidance

Sullivan & Cromwell LLP - March 18, 2020

AMF Takes Temporary Action to Prohibit Short Selling of All Publicly Traded Equity Securities on French Trading Venues in Response to Market Turmoil Related to COVID-19 Outbreak

Sullivan & Cromwell LLP - March 18, 2020

DSIO and DMO Issue No-Action Letters Granting Temporary, Conditional Relief to CFTC Registrants for Recordkeeping Requirements for Oral Communications, Time-Stamping Requirements and for the Filing of Annual Compliance Reports

Sullivan & Cromwell LLP - March 17, 2020

The Rise of ESG Metrics in Executive Compensation

Sullivan & Cromwell LLP - March 10, 2020

U.S. District Court for the District of Connecticut Finds That the Trial Evidence Did Not Support a Finding That the Defendant Was an Agent of a U.S. Company and Grants Post-Conviction Motion for Judgment of Acquittal of FCPA Charges

Sullivan & Cromwell LLP - February 28, 2020

The UK Competition and Markets Authority Breaks New Ground in Asserting Jurisdiction Over Mergers With no Effects in the UK

Sullivan & Cromwell LLP - February 19, 2020

Final Revisions to Rules for Foreign Investment Review by the United States Government Have Become Effective

Sullivan & Cromwell LLP - February 13, 2020

Amendment to FDIC Securitization Safe Harbor Rule to Limit Requirement to Comply with SEC Regulation AB to Public Offerings

Sullivan & Cromwell LLP - February 6, 2020

Court of Chancery Determines Deal Price Exceeds Fair Value, But Panera Is Not Entitled to a Refund Under the Appraisal Statute

Sullivan & Cromwell LLP - February 4, 2020

The UK Competition and Markets Authority issued new guidance on January 28, 2020 to provide clarity on how Brexit affects its jurisdiction after the UK leaves the EU on January 31, 2020

Sullivan & Cromwell LLP - January 31, 2020

Revised Jurisdictional Thresholds

Sullivan & Cromwell LLP - January 28, 2020

Court Rejects Argument That Stockholders Must Assert a Credible Basis of Actionable Wrongdoing to Obtain Books and Records and Places Burden on Company to Identify Relevant Documents

Sullivan & Cromwell LLP - January 17, 2020

CFTC Cross-Border Swaps Rule Proposal Addresses Registration Thresholds, ANE Transactions, and Substituted Compliance

Sullivan & Cromwell LLP - January 16, 2020

Sullivan & Cromwell LLP - January 14, 2020

FDIC and OCC Issue Notice of Proposed Rulemaking on Revisions to the Community Reinvestment Act Regulations

Sullivan & Cromwell LLP - January 10, 2020

SEC Senior Staff Joint Statement Includes Observations and Reminders for Audit Committees on Oversight of Financial Reporting

Sullivan & Cromwell LLP - January 7, 2020

Proposed Amendments Would Expand Persons and Categories of Entities that Qualify as Accredited Investors

Sullivan & Cromwell LLP - January 7, 2020

The Second Circuit Lowers the Standard for Proving Title 18 Insider Trading, Making It Easier for the Government to Bring Insider Trading Cases Where There Is No “Personal Benefit” to the Insider Who Discloses Information

Sullivan & Cromwell LLP - January 6, 2020

FSOC Finalizes Changes to Nonbank SIFI Designation Guidance

Sullivan & Cromwell LLP - January 2, 2020

Sullivan & Cromwell LLP - December 27, 2019

DOJ Policy Includes Concrete Benefits for Voluntary Self-Disclosure but Requires that Disclosure Be Made Directly to DOJ

Sullivan & Cromwell LLP - December 19, 2019

IAIS Adopts Global Frameworks for Supervision of Internationally Active Insurance Groups and Mitigation of Systemic Risk in the Insurance Sector

Sullivan & Cromwell LLP - December 18, 2019

Banking Agencies Finalize Rule Revising the Regulatory Capital Definition of High Volatility Commercial Real Estate Exposure

Sullivan & Cromwell LLP - December 12, 2019

Federal Bank Regulators Finalize Standardized Approach for Calculating the Exposure Amount of Derivative Contracts

Sullivan & Cromwell LLP - December 10, 2019

The Division Completed an Investigation of Standard-Setting Activities by Issuing a Business Review Letter, and Provided Guidance on Safeguards for Standard-Setting Organizations

Sullivan & Cromwell LLP - December 9, 2019

Banking Agencies Issue Final Supplementary Leverage Ratio Rule for Custodial Banks

Sullivan & Cromwell LLP - December 4, 2019

First Circuit reversed District Court Ruling that Held Two Affiliated Private Equity Funds Jointly and Severally Liable for their Bankrupt Portfolio Company’s Pension Liabilities

Sullivan & Cromwell LLP - December 2, 2019

Proposed Rules Reaffirm that a Valid Interest Rate on a Loan Originated by a Bank Remains Valid After the Loan Is Sold or Assigned to a Non-Bank

Sullivan & Cromwell LLP - November 21, 2019

ISS Updates Its 2020 Benchmark Proxy Voting Policies for the Americas, EMEA, and Asia-Pacific Regions, to Take Effect for Shareholder Meetings Held on or After February 1, 2020

Sullivan & Cromwell LLP - November 14, 2019

Sullivan & Cromwell LLP - November 6, 2019

Orders Impose Publication Requirements, Heightened Requirements for “Significant Guidance Documents,” and Restrictions on the Reliance on Guidance Documents in Certain Administrative Actions

Sullivan & Cromwell LLP - October 25, 2019

A Successful Appeal by the OCC Could Greatly Expand and Simplify the Ability of Certain FinTech Companies to Make Loans

Sullivan & Cromwell LLP - October 23, 2019

Pursuant to the draft Finance Bill for 2020, which is currently under discussion in the French Parliament, senior executives of large French companies will automatically become subject to French tax, irrespective of their having a permanent home, habitual abode and physical presence outside of France. Such reform is expected to be enacted by the end of the year and to enter into effect with respect to fiscal year 2019

Sullivan & Cromwell LLP - October 21, 2019

Banking Agencies Finalize Significant Revisions to the Application of Enhanced Prudential Standards and Capital and Liquidity Requirements to Large U.S. and Foreign Banking Organizations

Sullivan & Cromwell LLP - October 18, 2019

FRB Issues Notice of Proposed Rulemaking to Establish Capital Requirements for Savings and Loan Holding Companies Significantly Engaged in Insurance

Sullivan & Cromwell LLP - October 10, 2019

Treasury Proposes CFIUS Regulations to Implement Reforms Enacted Under the Foreign Investment Risk Review Modernization Act of 2018

Sullivan & Cromwell LLP - October 7, 2019

Court of Chancery Sustains Bad Faith Claim Alleging That the Board Ignored “Red Flags” Revealing Pharma Company’s Published Clinical Trial Data Flouted Governing Industry Protocols

Sullivan & Cromwell LLP - October 4, 2019

The European Court of Justice Has Found in Google’s Favor That Search Engine Operators Are Not Required to Carry Out Global De-Referencing

Sullivan & Cromwell LLP - October 1, 2019

SEC Adopts Rule Permitting All Issuers to Use “Test-the-Waters” Communications

Sullivan & Cromwell LLP - September 27, 2019

The Proposed Regulations Generally Would Extend Rules Applicable to Computer Programs to Other Digital Content, Provide Guidance for Classifying Cloud Transactions and Treat Sales of Downloaded Material Based on the User’s Location for U.S. Tax Purposes

Sullivan & Cromwell LLP - September 19, 2019

United States Refreshes and Enhances Cuba Sanctions – Developments Include Allowing Suits for Trafficking in Confiscated Cuban Property and Reimposing Previously Lifted Restrictions

Sullivan & Cromwell LLP - September 17, 2019

SEC Issues Proxy Voting Guidance and Interpretation (1) Confirming Proxy Voting Responsibilities of Investment Advisers, Including That Advisers Are not Required to Vote all Client Securities and That Voting Must Place Client Interests Ahead of the Adviser’s Own Interests and (2) Clarifying That Federal Proxy Rules Apply to Proxy Voting Advice; SEC Staff Continues to Consider Further Rulemaking

Sullivan & Cromwell LLP - August 26, 2019

Governor Cuomo Signs Bills That Loosen the Legal Standards Governing Sexual Harassment and Discrimination Claims, Ban Salary History Inquiries in Connection with Hiring, Expand the Scope of the State’s Equal Pay Act, and Prohibit Race Discrimination Based on Natural Hair or Hairstyles

Sullivan & Cromwell LLP - August 21, 2019

Proposal Would Make Disclosures of Business and Risk Factors More Principles-Based and Update Certain Requirements for Disclosure of Legal Proceedings

Sullivan & Cromwell LLP - August 12, 2019

Amendments to Rules 5130 and 5131 Would Expand and Clarify Various Specific Exemptions and Align the Rules’ Anti-Dilution Provisions

Sullivan & Cromwell LLP - August 2, 2019

Proposed Settlement Requires Facebook to Pay a Record-Breaking $5 Billion Penalty, Modify Its Corporate Governance Structure, and Submit to Third-Party Oversight of Its Privacy Program

Sullivan & Cromwell LLP - July 26, 2019

Sullivan & Cromwell LLP - July 25, 2019

Identifies Compliance Challenges for Broker-Dealers Seeking to Custody Digital Asset Securities and Welcomes Ongoing Engagement With Industry on Proposed Methods to Comply

Sullivan & Cromwell LLP - July 18, 2019

Antitrust Division Reverses Longstanding Policy of Refusing to Consider Compliance Programs in Charging Decisions and Issues Detailed Guidance for Assessing Effectiveness of Antitrust Compliance Programs

Sullivan & Cromwell LLP - July 15, 2019

Sullivan & Cromwell LLP - July 12, 2019

Federal Reserve Eliminates Standalone Prior Approval Requirement for Common Stock Repurchases

Sullivan & Cromwell LLP - July 9, 2019

New Loan Standards, Proposed EU Green Bond Standard and Other Recent Developments

Sullivan & Cromwell LLP - July 8, 2019

October Term 2018

Sullivan & Cromwell LLP - July 3, 2019

The SEC Issues Comprehensive Request for Comment on the Framework for Exempt Offerings under the Securities Act

Sullivan & Cromwell LLP - July 1, 2019

United States Supreme Court Rules for Taxpayer in Trust State Income Taxation Case

Sullivan & Cromwell LLP - June 28, 2019

Basel Committee Significantly Revises Leverage Ratio Treatment of Client Cleared Derivatives and Introduces New Leverage Ratio Disclosure Requirements

Sullivan & Cromwell LLP - June 27, 2019

United States Sanctions Iran’s Supreme Leader and the Supreme Leader’s Office, and Expands Sanctions Authorities Targeting Iranian Officials and Front Companies; Foreign Financial Institutions That Conduct Transactions for the New Sanctions Targets Also May Be Sanctioned

Sullivan & Cromwell LLP - June 26, 2019

Court Holds That, Under FOIA, the Federal Government May Not Disclose Commercial Information That a Corporation Has Kept Private and Provided to the Government Under an Assurance of Privacy

Sullivan & Cromwell LLP - June 25, 2019

The Court Finds Bad Faith Adequately Pled by Allegations That Company Had No Board Level System for Monitoring or Reporting on Food Safety Issues

Sullivan & Cromwell LLP - June 20, 2019

Proposal Provides Greater Clarity, but Does not Address a Number of Key Issues

Sullivan & Cromwell LLP - June 17, 2019

FinCEN Issues Updated Convertible Virtual Currency Guidance

Sullivan & Cromwell LLP - June 14, 2019

Supreme Court Unanimously Holds That Title VII’s Pre-Suit Administrative Charge Requirement Is Not Jurisdictional and Can Be Waived If Employers Do Not Timely Object

Sullivan & Cromwell LLP - June 4, 2019

The SEC Proposes Amendments and Interpretive Guidance Addressing the Cross-Border Application of Certain Security-Based Swap Requirements

Sullivan & Cromwell LLP - May 29, 2019

U.S. Supreme Court Permits Antitrust Claims Against Apple by Purchasers of iPhone Apps to Proceed Under Illinois Brick

Sullivan & Cromwell LLP - May 15, 2019

OFAC’s Framework Provides “Best Practices” Guidance; Identifies Five Essential Components of a Sanctions Compliance Program and Outlines Ten Root Causes of Apparent Violations of OFAC Sanctions Programs

Sullivan & Cromwell LLP - May 10, 2019

Employers Required To Submit 2017 and 2018 Pay Data by September 30, 2019; EEOC Appeal of Decision Reinstating Pay Data Rule Will Not Affect Deadline

Sullivan & Cromwell LLP - May 9, 2019

CFPB Requests Information to Address Potential Concerns Arising from Termination of Temporary Exemption

Sullivan & Cromwell LLP - May 3, 2019

DOJ Provides More Detailed Guidance for Assessing Compliance Programs in Determining the Nature, Form, and Consequences of Corporate Criminal Resolutions

Sullivan & Cromwell LLP - May 3, 2019

Sullivan & Cromwell LLP - April 29, 2019

U.S. Supreme Court Holds That an Ambiguous Arbitration Agreement Cannot Support Class Arbitration

Sullivan & Cromwell LLP - April 26, 2019

Federal Reserve Proposes Revision of Its Control Rules

Sullivan & Cromwell LLP - April 24, 2019

Federal Bank Regulators Propose Significant Revisions to the Application of Prudential Standards to Foreign Banking Organizations and Seek Comment on Whether to Impose Standardized Liquidity Requirements on their U.S. Branches and Agencies

Sullivan & Cromwell LLP - April 23, 2019

Federal Banking Agencies Propose Regulatory Capital Deductions for Investments by Advanced Approaches Banking Organizations in TLAC-Eligible Debt

Sullivan & Cromwell LLP - April 18, 2019

New EU Regulation Focuses on Cooperation Between Member States and the EU Commission

Sullivan & Cromwell LLP - April 15, 2019

Federal Bank Regulators Propose Significant Revisions to the Application of Prudential Standards for Foreign Banking Organizations, Seek Comment on Whether to Impose Standardized Liquidity Requirements on Their U.S. Branches and Agencies, and Propose Significant Revisions to Resolution Planning Requirements

Sullivan & Cromwell LLP - April 8, 2019

SEC Proposes an Overhaul of the Registration, Offering and Communications Processes and Other Aspects of the Disclosure and Regulatory Framework for Business Development Companies and Registered Closed-End Funds to Provide Parity with Operating Companies

Sullivan & Cromwell LLP - April 1, 2019