SEC Release No. 34-65164; SR-NYSE-2011-43 August 18, 2011 The SEC declared immediately effective an NYSE proposal to delete NYSE Rule 92, which limits trading ahead of customer orders and to adopt NYSE Rule 5320, which is substantially the same as FINRA Rule 5320. Rule 5320 generally prohibits trading ahead of customer orders, subject to certain exceptions such as for large orders and institutional accounts, riskless principal trades, odd lot and bona fide error transactions, and others. For more information about this document, you may contact one of the following Cadwalader attorneys: Steven

76 FR 52996 August 18, 2011 Pursuant to authority under the Dodd-Frank Act, the SEC approved a temporary PCAOB rule to establish an inspection program for audits of brokers and dealers. Cross References: 76 FR 40961 (Proposal; SEC Release No. 34-64814) Sarbanes-Oxley § 107(b), Exchange Act § 19(b)(1), PCAOB Rule 1001, Dodd-Frank § 982

76 FR 52040 August 15, 2011 The SEC granted accelerated approval to a FINRA proposal to amend the supplementary material to its recently-adopted Rule 1230, which requires registration and imposes certain other requirements on operations professionals. The rule change is intended to provide that employees of foreign broker-dealers whose activities with respect to the customers of a FINRA member are limited to the facilitation of the clearance and settlement of transactions in foreign securities are not subject to the registration requirement of Rule 1230(b)(6)(A). The exception only applies

August 19, 2011 The Wolfsberg Group, a consortium of international banks dedicated to developing standards for anti-money laundering and counter-terrorist financing policies in the financial services industry, has published an update to its January 2009 guidance on issues arising from trade finance. The new version of the trade finance principles includes a series of new appendices with guidance on the application of anti-money laundering and counter-terrorist financing in the context of standby letters of credit and guarantees and open account trade transactions.

The Wolfsberg Group August 19, 2011 On the same day that it issued updated guidance on trade finance principles, the Wolfsberg Group also released an update to its 2007 Wolfsberg Statement against Corruption.The paper takes into account a number of recent developments, including the entry into force of the UK Bribery Act, and gives financial institutions advice on combating bribery risks which arise not only in relation to their clients but also within their own organisations. Cross References Wolfsberg Group Publishes Updated Trade Finance Principles