United States: Asset Management Spotlight (January 2026 – February 2026)

In brief

From January 2026 to February 2026, US regulators advanced several notable initiatives affecting alternative asset managers and financial market participants, reflecting continued regulatory focus on reporting modernization, digital assets, market integrity, and sanctions policy.

Key developments are summarized below:

• US Commodity Futures Trading Commission (CFTC):
  • Issued no-action relief delaying enforcement of the Part 17 large trader reporting rule;
  • Released an interpretive letter confirming the continued legacy status of certain Morgan Stanley swaps;
  • Expanded eligibility for payment stablecoins issued by national trust banks under updated collateral guidance, and
  • Published market advisory regarding insider trading in connection with event contracts and prediction markets.
• US Securities and Exchange Commission (SEC):
  • Through reports issued by the Division of Economic and Risk Analysis (DERA):
    • Highlighted the rapid growth of active exchange-traded funds (ETFs) and
    • Analyzed fee reductions linked to fund mergers, with a focus on investor costs impacts.
• Office of Foreign Assets Control (OFAC):
  • Following the issuance of General Licenses 46, 47, and 48, OFAC issued General Licenses 49 and 50 authorizing limited, highly conditioned engagement in Venezuela’s oil and gas sector.
• Firm Developments:
  • Baker McKenzie launched its mobile-friendly Global Data & Cyber Handbook Lite, designed to provide easier access to core data protection requirements across multiple jurisdictions.

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