Cleary Discusses Labor Department’s Proposed Rule on 401(k)s and Alternative Assets

On March 30, 2026, the U.S. Department of Labor (the DOL) published its heavily anticipated proposed rule entitled “Fiduciary Duties in Selecting Designated Investment Alternatives” (the Proposed Rule).[1] Over the years, sponsors of private funds and other investment vehicles …

Sullivan & Cromwell Discusses FinCEN, OFAC Proposed Rule on Anti-Money Laundering and Sanctions-Compliance Requirements

On April 8, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”) jointly issued a notice of proposed rulemaking (“NPR”) to address anti-money laundering (“AML”) and countering the financing …

Paul Weiss Discusses OFAC Guidance on “Sham Transactions” and Sanctions Evasion

On March 31, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a sanctions advisory providing guidance on sham transactions used to evade U.S. sanctions (the “Sanctions Advisory”).[1] The Sanctions Advisory identifies specific red …