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The Beginning of the End of the End: Transitioning Loans and Derivatives from USD LIBOR in 2021

Client Alert | 1 min read | 03.10.21

On March 5, the UK’s Financial Conduct Authority announced the dates on which USD and other LIBOR settings will cease to be published, officially marking the long-anticipated beginning of the end of a multi-year process to terminate LIBOR and transition markets to new benchmark rates. 

In this client alert, Julia Lu and John A. Clark compare model USD LIBOR fallback approaches that have been promulgated by policymakers and industry leaders in the U.S. syndicated loan market, on the one hand, and the over-the-counter derivatives market, on the other, and discuss two alternative strategies for market participants seeking to minimize basis risk arising from different fallback approaches.

Click here to read the client alert. 

Insights

Client Alert | 3 min read | 08.18.25

FCPA Enforcement Continues to Evolve with Newly Unsealed Indictment

On August 11, 2025, the U.S. Department of Justice (“DOJ”) announced that it had unsealed an indictment against two Mexican businessmen for alleged violations of the Foreign Corrupt Practices Act (“FCPA”). DOJ asserts that the defendants, both Mexican nationals living in Texas, paid bribes to officials at Petróleos Mexicanos (“PEMEX”), and its subsidiary, PEMEX Exploración y Producción (“PEP”) to secure contracts worth an estimated $2.5 million. These charges come amidst a period of uncertainty regarding FCPA enforcement following the Trump administration’s temporary pause on FCPA enforcement and the subsequent issuance of new investigation and enforcement guidelines....