The IRS has issued a revised Form W-8IMY that will be used by a non-U.S. nominee, intermediary or foreign partnership to certify its claimed FATCA status. This is the form used by foreign companies to certify that they are not the beneficial owners of the U.S. source income, but are acting on behalf of the beneficial owner. As with the Form W-8BEN-E that was recently issued, the revised Form W-8IMY contains multiple FATCA categories that can be claimed by the intermediary. Similarly, as with Form W-8BEN-E, no instructions have yet been issued for Form W-8IMY.Meanwhile, IRS officials reportedly

U.S. Senator Bob Corker (R-TN), the ranking member of the Senate Foreign Relations Committee, introduced legislation on April 30, 2014, providing for the imposition of more aggressive sanctions against Russia, including measures directed against all Russian senior officials, the country's largest energy companies and Russian financial institutions. In a statement, Senator Corker took exception to what he described as the Obama Administration's reactive approach to the crisis in Ukraine, and expressed his desire to "inflict more direct consequences on Russia prior to Vladimir Putin taking

On April 29, 2014, the Director of the Division of Corporation Finance issued a much-anticipated statement regarding the SEC's conflict minerals reporting requirements. Two weeks ago, the United States Court of Appeals for the District of Columbia Circuit held that portions of the SEC's conflict minerals rule violated the First Amendment by requiring companies to describe their products as having "not been found to be DRC conflict free." Since that decision, the SEC has faced significant pressure from opposite directions regarding the implementation of the rule. On April 21, 2014, twelve

The National Futures Association ("NFA") issued an Investor Newsletter for April 2014 that highlighted recent "scam trends," described recent enforcement actions and discussed the CFTC's whistleblower program. Of particular interest is the newsletter's statement that the CFTC's whistleblower program is going to "up the ante" in 2014. The NFA speculates that 2014 "could be a big one" for CFTC enforcement actions due to increased whistleblower involvement. The NFA notes that the CFTC received 58 whistleblower claims filed in fiscal year 2012 and 138 in fiscal year 2013 and, in 2014, the CFTC

FINRA issued a regulatory notice requesting comments on a revised proposal that would require a hyperlink to BrokerCheck in online retail communications that are produced by a FINRA member firm. The revised proposal includes changes made in response to comments on a prior proposal to amend FINRA Rule 2267 ("Investor Education and Protection"). Specifically, the revised proposal would require a firm to include a "readily apparent" reference and hyperlink to BrokerCheck on each of the firm's Web sites that are available to retail investors. In addition, it would require a firm to include a