Compliance Bricks and Mortar for July 21

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These are some of the compliance-related stories that recently caught my attention.


Developments in the Asset Management Industry by Itzhak Ben-David in the HLS Forum on Corporate Governance and Financial Regulation

The rising concentration in the asset management industry and the rise of ETFs not only change the way investors invest, but also affect the character of the securities market. Large asset managers induce non-fundamental volatility through large trades, and ETFs propagate liquidity shocks originated by investors. Furthermore, arbitrageurs, and specifically hedge funds, may not always absorb and correct these shocks and may even contribute to the noise in prices. [More…]


Treasury fines Exxon Mobil $2 million for violating Russia sanctions while Secretary of State Tillerson was CEO

OF AC considered the following to be aggravating factors: (1) ExxonMobil demonstrated reckless disregard for U.S. sanctions requirements when it failed to consider warning signs associated with dealing in the blocked services of an SDN; (2) ExxonMobil’s senior-most executives knew of Sechin’ s status as an SDN when they dealt in the blocked services of Sechin; (3) ExxonMobil caused significant harm to the Ukraine-related sanctions program objectives by engaging the services of an SDN designated on the basis that he is an official of the Government of the Russian Federation contributing to the crisis in Ukraine; and (4) ExxonMobil is a sophisticated and experienced oil and gas company that has global operations and routinely deals in goods, services, and technology subject to U.S economic sanctions and U.S. export controls. [More..]


The Case Of The Wholly Owned, But Not Totally Held, Subsidiary That May Or May Not Be 100% Owned by Keith Paul Bishop in California Corporate & Securities Law

When someone says that a subsidiary is “wholly owned”, I believe that the common understanding is that the parent company owns all of the issued and outstanding equity of the subsidiary. What if the statement is that the subsidiary is “totally” or “100%” owned? I suspect that most people would not intuit a different understanding. The Securities and Exchange Commission, however, assigns different meanings to each of these terms at least so far as financial statements are concerned. Here are the three definitions:… [More…]


LEI: more than a number

Corporates trading across many asset classes in Europe using derivatives should take note that from 3rd January 2018, any firm subject to MiFID II transaction reporting obligations will not be able to execute a trade for a client who is eligible for a Legal Entity Identifier (LEI) and does not have one. [More…]


Fed Nominee Randal Quarles in His Own Words by Ryan Tracy in the Wall Street Journal

“In some ways Dodd-Frank was not ambitious enough, and in other ways it was overly ambitious and I think there are lots of ways to refine Dodd-Frank and other forms of regulatory policy in ways that would be beneficial to the economy.” [More…]


On Pan-Mass Challenge weekend, August 4 – 6, I will saddle up to ride with 6,200 other cyclists to raise money for life-saving cancer research and treatment at Dana-Farber Cancer Institute. 100% of your donation will go to cancer research and treatment at Dana-Farber Cancer Institute through its Jimmy Fund. I have made a personal commitment to raise $8000.00. I hope, that as a reader of Compliance Building, you will support my fundraising effort. You can donate through any of the following links:

Thank you,
Doug

Author: Doug Cornelius

You can find out more about Doug on the About Doug page

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