FSR and Corporate Crime Notes

Hong Kong Monetary Authority proposes mandatory reference checking scheme to address “rolling bad apples” phenomenon

On 8 May 2020, the Hong Kong Monetary Authority (HKMA) commenced a three-month industry consultation on a proposed framework for a mandatory reference …

Sustainable finance in Hong Kong: Establishment of cross-agency steering group and upcoming developments

On 5 May 2020, five financial regulators and two government bureaux published a joint statement to announce the establishment of the Green and …

LIBOR Transition: Is ARRC’s Proposed Legislative Fix Constitutional?

In early March, 2020, the Alternative Reference Rates Committee (ARRC) in the US published a proposal for New York legislation to assist the …

The month ahead in financial services regulatory developments…

No “directing mind and will” found in SFO prosecution of Barclays

OFAC Issues Finding of Violation — but No Penalty — for Sanctions Violations Caused by Compliance System Defects and Human Error

On April 30, 2020, the US Department of Treasury (“Treasury”)’s Office of Foreign Assets Control (“OFAC”) issued a Finding of Violation to …

LIBOR transition: The risks of interim milestone delay for the cash market due to COVID-19

Malaysia: Section 17A of the MACC Act: TRUST-ed Adequate Procedures for your corporation

As discussed in our previous bulletin, Malaysia is anticipating the new corporate liability provision, i.e. Section 17A of the Malaysian Anti-Corruption …

COVID-19: Pressure Points: Impact on UK criminal investigations & justice system

German Ministry of Justice releases official draft Corporate Sanctions Act

Germany is progressing towards a corporate sanctions law addressing the criminal conduct of companies, regarding executive bodies, managers and employees …

OFSI imposes fourth monetary penalty in respect of financial sanctions

ISDA pre-cessation fallback consensus: will this reduce legacy LIBOR risk in the derivatives market?