European Securities and Markets Authority February 23, 2012 The European Securities and Markets Authority has published a discussion paper on the key concepts of an Alternative Investment Fund Managers Directive (AIFMD) and the types of AIFM. ESMA is seeking the views of external stakeholders on the policy orientations it has identified in order to progress its work to achieve a harmonised application of the Directive, and might consider developing some additional convergence tools for this purpose in future. The closing date for receipt of comments is March 23, 2012.

77 FR 13490 March 7, 2012 The SEC is making technical amendments to the rule under which former SEC members and employees are required to file a statement with the SEC concerning their practice outside the government. The amendments change the office responsible for processing these statements and provide a means of filing a statement electronically. Effective Date: March 7, 2012 Cross References: Exchange Act Section 23(a)(2); SEC Conduct Rule 8(b); 17 CFR § 200.735-8.

Financial Services Authority February 15, 2012 The FSA has imposed a financial penalty of £350,000 on Andrew Osborne for engaging in the market abuse offence of improper disclosure in breach of section 118(3) of FSMA. Andrew Osborne was, at the time of the offence, a managing director in the corporate broking group of Merrill Lynch International who were acting for Punch Taverns as joint book runner and co-sponsor in relation to a transaction to issue new equity.

International Swaps and Derivatives Association March 1, 2012 Following the submission of two potential Credit Event questions on February 28, 2012, the ISDA EMEA Determinations Committee has declared that a Credit Event has not occurred in Greece. The Committee noted that as the situation in Greece is still evolving, market participants should feel free to submit further questions and that a Credit Event could occur at a later date should further facts come to light.

Financial Action Task Force February 16, 2012 The Financial Action Task Force (FATF) has revised its Recommendations after more than two years of efforts by member countries. The revised FATF Recommendations now fully integrate counter-terrorist financing measures with anti-money laundering controls, introduce new measures to counter the financing of the proliferation of weapons of mass destruction, and they will better address the laundering of the proceeds of corruption and tax crimes. They also strengthen the requirements for higher risk situations and allow countries to take a more