On March 31, 2014, the United States and the Republic of Honduras entered into an Intergovernmental Agreement ("IGA") to implement FATCA. The text of the IGA has just been published by the U.S. Treasury Department. The IGA is a Model 1A (Reciprocal) Agreement under which financial institutions in Honduras will provide information about financial accounts held directly or indirectly by certain U.S. persons to the Honduran Government which will automatically transmit such information to the U.S. IRS. In return, the United States agrees to require financial institutions in the United States to

Rising tensions in eastern Ukraine, where earlier this week pro-Russian demonstrators seized government buildings and called for a referendum on independence from Kiev, have led to renewed talk in Washington and Brussels of additional sanctions against Russian and Ukrainian individuals and entities and, potentially, against entire sectors of the Russian economy. Notwithstanding the polemics, Western leaders have so far refrained from adopting any significant new sanctions. Only the United States enacted any new measures, announcing on April 11 travel bans and asset freezes against seven

SIFMA Asset Management Group ("SIFMA AMG") released the results of a survey to determine separate accounts' vulnerability to systemic risk. SIFMA AMG surveyed nine asset managers on a number of issues, including investment strategy, use of leverage, investment in illiquid assets, use of securities lending, the regulatory status of the underlying clients, and risk management processes. The survey found that separate accounts do not typically pose risk to financial stability. Specifically, the survey found that in separate accounts with greater than $75 million in assets under management (AUM)

With less than two months until FATCA becomes effective, negotiations between the United States and Russia over the terms of an Intergovernmental Agreement to implement FATCA for Russian Financial Institutions have apparently stalled. On April 11, Russian Finance Minister Anton Siluanov met with U.S. Secretary of the Treasury Jack Lew in Washington to discuss a number of financial matters, but Siluanov indicated that the most pressing discussion points during the meeting concerned the prospects of signing an IGA as soon as possible. Progress on the agreement reportedly stalled in early April

In his recent post on the Harvard Law School's Forum on Corporate Governance, SEC Commissioner Luis A. Aguilar republished remarks made at the Mutual Fund Directors Forum's 2014 Policy Conference on April 2. Lofchie Comment: Commissioner Aguilar's speech was notable for its criticism of the FSOC's intrusion into areas of the expertise and authority of the SEC, particularly the FSOC's intrusion into the regulation of mutual funds. While the two Republican Commissioners had criticized the FSOC previously, Commissioner Aguilar effectively made critical views on FSOC the bipartisan and majority