Shadow SEC Statement No. 8: Comment on SEC Proposal to Allow Companies to File Semiannual Reports on New Form 10-S in Lieu of Quarterly Form 10-Q Filings

In a statement published last September, here, we argued that the SEC should maintain its current system of mandatory quarterly reporting and not adopt President Trump’s recommendation that the United States shift to a system based on six-month filings.  …

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 …