The Unibanco Letters - Dual-Hatting Regulations and Global Enforcement

The New Rule (Cont.) (3) Administrative Sanctions/Penalties • Impose business improvement orders, business suspension orders, and business cessation orders on Article 63 filers • Order the production of reports, file materials, or conduct inspections of Article 63 filers • Court order to cease or suspend the conduct of the business if there is an urgent situation requiring steps to prevent the escalation of damages or harm to investors Impose more severe penalties on a person who fails to file an Article 63 Notification or files a false notification (4) Limit the Scope of Investors • Eliminate cases where protection of investors would be hindered by the Article 63 Exemption Morgan Lewis 22

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