Mr. Lebedev is an associate in Davis Polk's Financial Institutions Group. [Full Bio]

The banking sector should pay close attention to the recent bipartisan bill supporting marijuana legal reform (the “Strengthening the Tenth Amendment Through Entrusting States Act” or the “STATES Act”) given the increasing difficulty current law creates even for those banks that are deliberately avoiding the cannabis sector.  Post mid-term elections,
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Buried in the latest Treasury Report, the third in a series, are important gems on the Volcker Rule and on the concept of controlling influence.[1]  Of the three interesting new recommendations, two are limited to the covered funds portion of the Volcker Rule and build upon the recommendations in the
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The Office of the Comptroller of the Currency (the “OCC”) took a first formal step in evaluating how the regulations implementing the Volcker Rule should be revised by issuing a request for public input on the regulations in early August, with comments due in late September.  Of the 55 comment
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The Trump administration’s first certification to Congress regarding Iranian nuclear compliance focused more on Iran’s support for terrorism and the initiation of a National Security Council review of the Joint Comprehensive Plan of Action (the “JCPOA”) than on the confirmation that Iran remains in compliance with its JCPOA commitments. The
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Both responding and contributing to the general escalation of tensions between the United States and Iran, a bipartisan group of senators consisting of seven Democrats and seven Republicans introduced a bill on March 23, 2017 to impose new sanctions on Iran in connection with that country’s ballistic missile program and
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On January 10, 2017, Senators Cardin (D-MD), McCain (R-AZ), Menendez (D-NJ), Graham (R-SC), Shaheen (D-NH), Rubio (R-FL), Klobuchar (D-MN), Sasse (R-NE), Durbin (D-IL) and Portman (R-OH) introduced a bill (S.94) that would expand and strengthen United States sanctions targeting Russia. The proposed legislation would, among other things, codify in statute
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On December 1, 2016, the Financial Action Task Force (“FATF”) released a peer assessment of the United States’ anti-money laundering and combatting the financing of terrorism (“AML/CFT”) regime.  This is the first peer assessment of the United States since June 2006.

The FATF assessment found that the U.S. AML/CFT framework
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