As we emerge from the midterm election season, we have updated our brief deck summarizing the leadership and staffing changes among federal financial regulators, including announced nominations, confirmations, resignations and expiring terms.  The first slide summarizes the state of play for the agencies’ principals; the later slides provide a deeper
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Financial services regulatory reform will continue to evolve in 2018 and 2019.  As we observe the changing legislative landscape, here is the Post Midterm Election Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue
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As we discuss in our memorandum released today and available here, the Hong Kong Securities and Futures Commission (“SFC”) last week took a significant step in its regulation of virtual asset activities by establishing a new, opt-in regulatory sandbox framework for virtual asset trading platform operators, proposing
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The Federal Reserve has finalized a new supervisory ratings system for large financial institutions (LFIs), discussed in our visual memorandum here.  The new LFI rating system, which reflects the three core areas of focus in the Federal Reserve’s current LFI supervisory framework—capital, liquidity and governance and controls—is
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On October 11, 2018, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a lengthy “Advisory on the Iranian Regime’s Illicit and Malign Activities and Attempts to Exploit the Financial System,” (the “Iran Advisory”), which provides examples and typologies of the Iranian regime’s exploitation
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After a several-year pause, the CFTC is again re-assessing its approach to cross-border regulation of swap activities. The CFTC’s current approach is embodied in various rulemakings, guidance, orders, and agreements with non-U.S. regulators that have been adopted, issued, and entered into since 2013. The CFTC has, over the past several
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On October 11, 2018, the SEC reopened the comment period and requested additional comments for previously proposed rules relating to capital, margin, and segregation requirements for security-based swap dealers (“SBSDs”), major security-based swap participants (“MSBSPs,” and together with SBSDs, “SBS Entities”) and, in some
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On October 5, 2018, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced that it had entered into an approximately $5.3 million civil monetary settlement with JPMorgan Chase Bank, N.A. (“JPMC”) for apparent violations of the Cuban Assets Control Regulations, 31 C.F.R. Part 515, the
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It is no secret that the United States lags behind other countries in the development of a national real-time payments infrastructure.[1]  There are, of course, explanations for this lag, including widespread participation in the existing infrastructure rails and the existence of many different stakeholder interests limiting consensus over reforms. 
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