HSR Early Terminations Suspended — On February 4, the Federal Trade Commission (FTC) announced that it was temporarily suspending the grant of Early Terminations of the 30-day Waiting Period for mergers and acquisitions that require notification under the Hart Scott Rodino Act.
Continue Reading FTC and DOJ Temporarily Suspend Early Termination of Hart-Scott-Rodino Waiting Periods

On October 1, the United States Department of Justice (DOJ) issued a favorable business review letter to the International Swaps and Derivatives Association (ISDA) that clears the way for ISDA to complete its work on developing standard amendments to swap documents to account for the discontinuation of LIBOR and other interbank offered rates (collectively, IBORs).
Continue Reading ISDA Efforts to Help Markets Deal With LIBOR Replacement Clear DOJ Hurdle

In response to the COVID-19 pandemic, the staffs at the Federal Trade Commission (FTC) and Department of Justice (DOJ) responsible for Hart-Scott-Rodino (HSR) merger reviews are working remotely. Accordingly, HSR filings cannot be made in hard copy — which is the only way those filings have been made in the past. In order address this situation, the FTC Premerger Notification Office has set up a temporary electronic platform to enable parties to make their HSR filings electronically. The new platform went live on Tuesday, March 17. Given the dislocations caused by these changes, the FTC has advised that it will not be granting Early Termination of the HSR Waiting Period on electronic filings at this time. Accordingly, parties who need HSR clearance on their transactions should factor in a full 30 days for HSR clearance in setting their timetables for closing.
Continue Reading COVID-19 Update – Hart-Scott-Rodino Filings

The US Attorney’s Office in the Northern District of California recently settled an enforcement action against Ripple Labs Inc., a Delaware corporation providing virtual currency exchange services. According to the settlement agreement, Ripple Labs was not registered with the Financial Crimes Enforcement Network (FinCEN) as a money services business (MSB) pursuant to the Bank Secrecy Act of 1970 while engaged in currency trading, and lacked required anti-money laundering controls.
Continue Reading Department of Justice Settles Virtual Currency Enforcement Action