HSBC (along with the OCC) was severely criticized in a Senate Report for violations of AML requirements and of OFAC procedures. The principal findings of fact regarding HSBC was that (i) its AML procedures were generally extremely weak; (ii) it did not identify its high risk affiliates (particularly in the Middle East and Mexico) and treat them accordingly; (iii) it overrode its own OFAC procedures; (iv) it provided services to non-U.S. banks that had been linked to terrorist financing; (v) it engaged in overtly suspicious transactions involving U.S. travelers checks that were obtained in

SEC Trading Division Director, Robert Cook testified before the Senate Committee on Agriculture, Nutrition and Forestry, regarding the impact of Dodd-Frank. Director Cook stated that the SEC was now at work on the "last of the core elements" of its planned regulation of swap dealers: the rules related to financial responsibility. He also noted that the SEC was taking a very careful approach to the cross-border application of Title VII and, in this regard, the SEC was "continuing to consider" the approach taken by the CFTC, but had not made a definitive decision as to its own alternatives. View

Grant of Exchange Act Rule 13e-4relief for a non-listed real estate investment trust that will offer securities that may be purchased and redeemed on a daily basis at a price based on the REIT's net asset value. View letter in full here (links externally to SEC website).

The SEC issued an order DISAPPROVING a number of proposed rule changes that the NYSE and NYSE Amex (collectively the SROs) had each filed with the SEC to amend certain of their respective rules relating to Designated Market Makers (DMMs) and Floor brokers. The SRO Proposals sought to amend the SRO's rules in 4 ways: Codify certain trading floor functions that may be performed by DMMs: Maintaining order among Floor brokers manually trading at the DMMs assigned panel. Bringing Floor brokers together to facilitate training. Assisting Floor brokers with respect to their orders by providing

Chairman Paredes expressed concern that the "Dodd-Frank regulatory regime goes too far" in injecting the government into business decisions and worried that the "present wave of regulation will prove to be excessive . . . " He discussed also the regulation of executive compensation and the proper role of the board of directors, including as to how dissent among the board might be encouraged. View release in full here (links externally to SEC website).