On April 8, 2019, the U.S. State Department announced its intent to designate Iran’s Islamic Revolutionary Guard Corps (“IRGC”) as a Foreign Terrorist Organization (“FTO”) under section 219 of the Immigration and Nationality Act, 8 U.S.C. § 1189.  The designation will take effect upon publication in…
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We recently wrote an article for Thomson Reuters’ Practical Law outlining the state of play for the financial services sector’s relationship with the U.S. cannabis sector.  Our article summarizes the dilemma arising from the widening gulf between static federal prohibitions and changing state laws.  We consider and reject a number…
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Cannabis banking legislation reached a new milestone last week. Following a markup session, the House Financial Services Committee on March 28 approved an amended SAFE Banking Act in a 45-15 vote. As our visual memorandum discussed in February, the bill offers a safe harbor and other protections for depository institutions…
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Earlier this month, SEC Chairman Jay Clayton and Division of Trading and Markets Director Brett Redfearn engaged in a public dialogue on equity market structure issues.  In addition to reviewing three equity market structure initiatives adopted by the SEC in 2018 (the transaction fee pilot, enhanced order handling …
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On April 1, 2019, new cybersecurity requirements outlined in the NFA’s Interpretive Notice to NFA Compliance Rules 2-9, 2-36 and 2-49 will come into effect.  These new requirements apply to NFA Members, including registered futures commission merchants, commodity trading advisors, commodity pool operators, introducing brokers, retail foreign exchange dealers, and…
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U.S. federal banking regulators plan to revive efforts to regulate financial institution incentive compensation, as required under Section 956 of the Dodd–Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act).  The Wall Street Journal reports that the current effort is in its “early stages” and is being…
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On March 4, 2019, the U.S. State Department announced that, for the first time, it would permit actions under Title III of the Cuban Liberty and Democratic Solidarity (Libertad) Act of 1996, Pub. L. 104-114 (the “Libertad Act”), which authorizes U.S. nationals that own claims to property…
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As the new Congress gets underway, 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 look on…
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Financial services regulatory reform continues to evolve in 2019.  As we observe the changing landscape, here is the New Congress 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 to track these issues and…
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Cannabis legislation for banking is now getting more serious attention, as it should. On Wednesday, February 13, the Consumer Protection and Financial Institutions Subcommittee of the House Committee on Financial Services will convene a hearing entitled, “Challenges and Solutions:  Access to Banking Services for Cannabis-Related Businesses.” The hearing follows Chairwoman…
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