On August 1, 2014, the Financial Crimes Enforcement Network ("FinCEN") published a notice of proposed rulemaking ("NPRM") that, when final, would impose a new regulatory requirement on certain Covered Financial Institutions to identify beneficial owners of legal entity customers. Specifically, banks, brokers or dealers in securities, mutual funds and futures commission merchants and introducing brokers in commodities ("Covered Financial Institutions") will be required to obtain identifying information about the beneficial owners of legal entity customers. Before finalizing the NPRM, FinCEN

FERC announced it authorized Freeport LNG Development L.P. ("Freeport") to construct and operate facilities to liquefy and export domestic natural gas from its existing liquefied natural gas ("LNP") import terminal located near the city of Freeport, Texas. In addition, FERC authorized Freeport's Phase II Modification Project, which would revamp the previously authorized but unconstructed Phase II Project. The Phase II Modification Project comprises three major components: reorientation of the Phase II dock, modification of the transfer facilities, and modification of access roads at the

On July 29, 2014, the United States Court of Appeals for the District of Columbia issued its decision in American Meat Institute v. U.S. Dept. of Agriculture, and held that rational basis review applies to compelled disclosures, even in cases not involving consumer deception. At issue in American Meat was whether the U.S. Department of Agriculture's country-of-origin labeling rule (COOL) is "compelled commercial speech" and therefore a violation of the First Amendment. In its en banc decision, the D.C. Circuit analyzed Zauderer v. Office of Disciplinary Counsel, in which the U.S. Supreme Court

The CFTC issued two separate notices indicating that individuals may submit whistleblower award claims regarding Hunter Wise Commodities and RP Martin Holdings and Martin Brokers. The CFTC issues Notices of Covered Action for each enforcement action where a final judgment or order - by itself or together with prior judgments or orders in the same action issued after July 21, 2010 - results in monetary sanctions exceeding $1 million. Individuals who voluntarily provided the CFTC with original information that led to the successful enforcement of a Covered Action are eligible to claim an award

The Cayman Islands Tax Information Authority issued a revised version of Guidance Notes to assist businesses, their advisers and the Cayman Islands Tax Authority in their interpretation and compliance with obligations under the Intergovernmental Agreement between the United States and the Cayman Islands and the separate Intergovernmental Agreement between the United Kingdom and the Cayman Islands. The over 180-page document covers both the U.S. and the UK agreements and provides extensive guidance with respect to classification of entities under FATCA and the various due diligence and