On Friday, the European Union issued a new list of twelve individuals (ten Russians and two Ukrainians) subject to travel bans and asset freezes in connection with their role in "undermining or threatening the territorial integrity, sovereignty and independence of Ukraine." Notably, the EU list is limited to officials, lawmakers, and military officers-it does not include any entities or private businessmen (so-called "cronies" of President Putin's administration). In contrast, the most recent U.S. sanctions list (UKRAINE2), issued Thursday under Executive Order 13661, contained a number of

The SEC Division of Corporate Finance released a revised statement on well-known seasoned issuer ("WKSI") waivers where there has been a violation of law. The SEC's guidance provides that a "waiver, which could include conditions or undertakings, may be granted if a review of all of the facts and circumstances leads the Division to conclude that granting the waiver would be consistent with the public interest and the protection of investors." In making that determination, the SEC stated it will consider the nature of the violation or conviction and whether it involved disclosure for which the

The CFTC's Division of Swap Dealer and Intermediary Oversight ("DSIO") issued a letter generally liberalizing the de minimis limits that would apply to an entity that is not registered as a swap dealer, but that seeks to enter into dealing swaps with certain power utilities that are within the definition of "special entity." Under the CFTC's swap dealer registration requirement, an entity that engages in as little as $25 million in notional swaps activity with a "special entity" could be required to register as a swap dealer. Under a prior CFTC no-action letter (CFTC Letter No. 12-18), this

The CFTC Division of Market Oversight ("DMO") issued a time-limited no-action letter extending relief for Multilateral Trading Facilities overseen by competent authorities designated by European Union Member States ("MTFs") from the swap execution facility ("SEF") registration requirement, pursuant to CEA Section 5h(a)(1) ("Swap Execution Facilities") and CFTC Rule 37.3(a)(1) ("Requirements and Procedures for Registration"). Additionally, the letter extends relief to parties executing swap transactions on or pursuant to the rules of MTFs from the trade execution mandate set out in CEA Section

The CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") provided no-action relief to Mitsui Company Precious Metals, Inc. (“Mitsui”) regarding the annual reporting requirements for chief compliance officers ("CCOs") pursuant to CFTC Rule 3.3 ("Chief Compliance Officer"). In the letter, the CFTC found that given that Mitsui's fiscal year ends on March 31, 2014, and it was only required to register as a swap dealer as of the preceding December 31, it would not provide enough time to prepare and submit a full annual report under CFTC Rule 3.3. The letter allows the CCO to provide an