On November 27, 2019, the United States Department of Commerce issued an advance notice of proposed rulemaking seeking public comment on “regulations that would govern the process and procedures that the Secretary of Commerce will use to identify, assess, and address certain information and communications technology and services transactions that
Continue Reading U.S. Department of Commerce Proposes Rule Governing Information and Communications Technology and Services

For hemp-related customers, banks no longer need to file suspicious activity reports according to a guidance statement issued by the Federal Reserve, FDIC, OCC and FinCEN, in consultation with the Conference of State Bank Supervisors. The descheduling of hemp from the Controlled Substances Act eliminates the need for banks to
Continue Reading Banking Hemp: The Banking Regulators Move Forward

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
Continue Reading Davis Polk Client Memorandum: United States Sanctions Turkish Government over Syrian Incursion

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
Continue Reading Cannabis Legalization? — Updated Briefing on the SAFE Banking Act, the STATES Act and the MORE Act

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
Continue Reading U.S. Imposes Additional Sanctions on Central Bank of Iran

Financial services regulatory reform continues to evolve in 2019.  As we observe the changing landscape, here is the Fall Focus 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
Continue Reading Davis Polk Financial Services Regulatory Reform Tool—Fall Focus Edition

For those following Congressional efforts to solve the challenges of banking the cannabis sector, we have updated our briefing on the two pending bills in light of the Senate Banking Committee hearing on Tuesday July 23 on “Challenges for Cannabis and Banking:  Outside Perspectives.”  We cover both of the two
Continue Reading Davis Polk Client Memorandum: Banking and Cannabis — Updated Briefing on the SAFE Banking Act and STATES Act

Financial services regulatory reform continues to evolve in 2019.  As we observe the changing landscape, here is the Summer Spotlight 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
Continue Reading Davis Polk Financial Services Regulatory Reform Tool—Summer Spotlight Edition

The House Financial Services Committee unanimously recommended to the full House on May 9, 2019 a bill that would reform the U.S. anti-money laundering (AML) regime.  H.R. 2514, the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act), would amend the Bank Secrecy Act
Continue Reading Bank Secrecy Act Reform Legislation Advanced Unanimously by House Financial Services Committee

A bipartisan group of 38 state and territorial attorneys general has signed an open letter to Congress calling for legislative change for banking and financial institutions wishing to provide services to cannabis businesses. The letter describes the severe financial restrictions faced by cannabis businesses that operate legally under state law
Continue Reading Bipartisan Support for Cannabis Banking Safe Harbor Reaches New High with Letter from Attorneys General