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,
Continue Reading Bipartisan Marijuana Bill Would Permit Banking Legal Cannabis Businesses

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
Continue Reading Treasury Asset Management and Insurance Report Makes Three Recommendations Tied to the Volcker Rule

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
Continue Reading Volcker Rule Commenters Largely Support Reforms

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
Continue Reading Nuclear Certification to Congress Confirms Iran’s Compliance but Stresses Policy Review

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
Continue Reading Bipartisan Group of Senators Introduces Countering Iran’s Destabilizing Activities Act of 2017

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
Continue Reading Bipartisan Group of Senators Proposes Expansion of Sanctions on Russia

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
Continue Reading FATF Reviews AML / CFT Regime