On April 10, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) jointly issued a notice of proposed rulemaking (NPRM) setting out their view of how sanctions, anti-money laundering and countering the financing of terrorism (AML/CFT) compliance requirements should apply to permitted payment stablecoin issuers (PPSIs) under the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. The agencies also issued an accompanying fact sheet. This NPRM follows Treasury’s earlier proposal on principles for acceptable state stablecoin regulatory...

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Lawyers, both in-house and in private practice are making growing use of generative AI in the delivery of legal services.  This had led to the creation of a whole new category of documents, in the form of prompts and AI outputs.  Such documents, as with any others, may be subject to disclosure in legal proceedings, unless protected by privilege. Recent rulings on both sides of the Atlantic have highlighted the growing tensions between the use of generative AI tools and...

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For European investors eyeing the U.S. market with an acquisition, the “Stock vs. Assets” debate is more than just a legal technicality; it dictates your future liability profile and tax efficiency. Whether you acquire shares of stock directly through a European legal entity (“European Entity”) or utilize a Delaware “Newco” to buy assets, your choice should align with your long-term risk tolerance and exit strategy. In our new alert, we outline two different acquisition scenarios, highlighting the benefits, opportunities, and...

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European Commission adopts RTS under EU Ratings Regulation The European Commission adopted two draft Delegated Regulations supplementing the ESG Ratings Regulation. The European Securities and Markets Authority (ESMA) consulted on the draft RTS in May 2025. Draft Delegated Regulation with regard to RTS specifying the measures and safeguards to be implemented by ESG rating providers to separate their ESG rating activities from their other activities Draft Delegated Regulation with regard to RTS specifying the elements of ESG rating products to...

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