On October 23, 2019, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) acting at the direction of President Trump and in consultation with the State Department, lifted sanctions on three Turkish government ministers and two Turkish government ministries and removed them from the List of Specially Designated…
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The FDIC and the Federal Reserve Board have solicited public comment on the use of the Uniform Financial Institutions Rating System, more commonly known as CAMELS ratings.  The release asks 10 questions, which focus on the ways in which the agencies use the CAMELS system, their consistency in doing so,…
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On October 14, 2019, President Trump issued an Executive order authorizing sanctions targeting the Turkish government in connection with its military operations in northern Syria. The U.S. government also announced a 50% tariff on imports of steel from Turkey and cancellation of trade agreement negotiations.

The initial sanctions announced by…
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The Federal Reserve has approved its long-awaited Final Rule amending and restating the 165(d) resolution planning rule. The FDIC is expected to soon approve an identical rule.  The Final Rule is largely unchanged from the Federal Reserve’s and FDIC’s May 2019 joint 165(d) Rule Proposal, and among other things:

  • Creates

…
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The Federal Reserve has finalized its rules to further tailor the regulatory framework for enhanced prudential standards and the U.S. Basel III capital and liquidity requirements applicable to domestic banking organizations and foreign banking organizations (Final Tailoring Rules).  Compared to the proposed rules that the U.S. banking agencies…
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Congress now has three different cannabis bills and three different approaches before it. One approach, taken by the Secure and Fair Enforcement Banking Act (the SAFE Banking Act), is to focus specifically on the difficulties faced by the banking, insurance and payments sectors. Another approach, taken by the Strengthening the…
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In a long-awaited milestone, the SEC has proposed an update of Guide 3, the industry guide for banking organizations.  The proposal eliminates a number of the current requirements under Guide 3 and streamlines many of those that remain.  The three “new” credit quality ratios in the proposal are, in practice,…
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In response to what Treasury Secretary Steven Mnuchin called “Iran’s brazen attack against Saudi Arabia,” and following President Trump’s tweet ordering Treasury to “substantially increase Sanctions on the country of Iran,” today the Treasury Department’s Office of Foreign Assets Control (OFAC) imposed additional sanctions on the Central Bank of Iran…
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In the latest development in the complex and evolving sanctions targeting the Government of Venezuela, on September 9, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 34,  The new GL authorizes transactions involving certain individuals that would otherwise be prohibited…
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