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BNP Paribas ("BNPP"), France's largest bank (and the world's fourth largest bank), pled guilty in New York State court to one count of Falsifying Business Records in the First Degree, in violation of New York Penal Law § 175.10, and Conspiracy in the Fifth Degree, in violation of New York Penal Law § 105.05(1), in connection with its role in concealing prohibited transactions involving entities in three sanctioned countries: Sudan, Iran and Cuba. BNPP also agreed to plead guilty in federal court to one count of conspiring to violate the International Emergency Economic Powers Act, 50 U.S.C. §

Steven Lofchie Commentary by Steven Lofchie

EU Commissioner for Internal Market and Financial Services Michel Barnier said he intends to propose that the European Commission ("EC") adopt "equivalence" decisions that will allow central counterparty clearing houses ("CCPs") from five countries outside the European Union to clear EU derivatives trades. The allowed countries will be Japan, Singapore, Australia, Hong Kong and India. Regarding the absence of the United States from the list, Commissioner Barnier noted that, if the CFTC gives effective equivalence to third-country CCPs, he is confident that the list will include the United

FINRA announced that it began publicly disseminating Securities Act Rule 144A ("Private Resales of Securities to Institutions") transaction data in corporate debt securities in order to "bring transparency to a market that had previously operated in the dark." Through the Trade Reporting and Compliance Engine, FINRA will disseminate 144A transactions subject to the same dissemination caps that are currently in effect for non-144A transactions. FINRA stated that the same dissemination cap for investment-grade corporate bonds, or $5 million, applies to both 144A and non-144A corporate bond

The Government of the British Virgin Islands and the United States signed a FATCA Intergovernmental Agreement ("IGA"). The IGA is a Model 1B (nonreciprocal) agreement, pursuant to which financial institutions and investment entities in the British Virgin Islands ("BVI") will provide information on their direct and indirect U.S. account holders to the BVI, which in turn will provide that information to the U.S. Internal Revenue Service. The IGA was signed at the Department of Treasury in Washington, D.C. by Premier of the BVI, the Honorable Dr. D. Orlando Smith, OBE, and by Assistant Secretary

The Clearing Firms Committee of SIFMA submitted comments to the SEC on FINRA's proposed rule change to NASD Rule 2340 ("Customer Account Statements"), which relates to estimated values of unlisted Direct Participation Programs ("DPPs") and Real Estate Investment Trusts ("REITs") on customer account statements. SIFMA stated that while it supports FINRA's efforts to design rules intended to improve customer protection and provide greater transparency in this area, it cannot support approval of the Proposed Rule Change for the same reasons as had been described in SIFMA's previous two comment