On November 19, 2018, the Commerce Department’s Bureau of Industry and Security (“BIS”) issued an advance notice of proposed rulemaking (“ANPRM”) seeking public comment on “criteria for identifying emerging technologies that are essential to U.S. national security.”[1] The ANPRM was issued pursuant to the Export Control Reform
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Economic Sanctions
U.S. Prosecutors and Regulators Impose Second Largest Penalty Ever Levied Against a Financial Institution for Violations of U.S. Economic Sanctions
On November 19, 2018, a group of five U.S. federal and state prosecutors and regulators[1] announced that they had reached settlements with Société Générale (“SocGen”) under which SocGen will pay penalties totaling $1.34 billion in relation to violations of U.S. economic sanctions concerning Iran, Cuba, Sudan and…
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Davis Polk Financial Services Regulatory Reform Tool—Post Midterm Election Edition
Posted in Administrative Law, Anti-Money Laundering, Bank Capital, Bank Regulation, BCFP, CFTC, Community Reinvestment Act, Cost-Benefit Analysis, Dodd-Frank, Economic Sanctions, FDIC, Federal Reserve, FinTech, FSOC, Legislation, Liquidity, OCC, OFAC, Stress Testing, Swap Regulation, TLAC, U.S. Basel III, U.S. Congress, Volcker Rule
Financial services regulatory reform will continue to evolve in 2018 and 2019. As we observe the changing legislative landscape, here is the Post Midterm Election 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…
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As Sanctions “Snap-Back” Approaches, FinCEN Advisory Emphasizes Risks to the U.S. and International Financial Systems Posed by Iran
On October 11, 2018, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a lengthy “Advisory on the Iranian Regime’s Illicit and Malign Activities and Attempts to Exploit the Financial System,” (the “Iran Advisory”), which provides examples and typologies of the Iranian regime’s exploitation…
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OFAC Enforcement Action Highlights Risk of Indirect Sanctions Violations, Importance of Acting on “Red Flags”
Posted in Economic Sanctions
On October 5, 2018, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced that it had entered into an approximately $5.3 million civil monetary settlement with JPMorgan Chase Bank, N.A. (“JPMC”) for apparent violations of the Cuban Assets Control Regulations, 31 C.F.R. Part 515, the…
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Russia Sanctions Updates
The past two weeks have seen a number of developments with respect to U.S. sanctions relating to Russia, as the Trump administration has (1) taken additional steps to ameliorate adverse consequences for U.S. persons of the significant sanctions actions targeting Russian oligarchs announced on April 6, 2018; (2) further implemented…
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Davis Polk Financial Services Regulatory Reform Tool—Fall Focus Edition
Posted in Administrative Law, Anti-Money Laundering, Bank Capital, Bank Regulation, BCFP, CFTC, Community Reinvestment Act, Cost-Benefit Analysis, Dodd-Frank, Economic Sanctions, FDIC, Federal Reserve, FinTech, FSOC, Legislation, Liquidity, OCC, OFAC, Stress Testing, Swap Regulation, TLAC, U.S. Basel III, U.S. Congress, Volcker Rule
Financial services regulatory reform in 2018 continues to evolve. As we leave summer behind, 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 will…
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President Trump Issues Executive Order Re-Imposing Iran Sanctions, Signals Aggressive Enforcement to Come
On August 6, 2018, President Trump issued Executive Order (“E.O.“) 13846, further implementing his May 8, 2018 decision to terminate the United States’ participation in the Joint Comprehensive Plan of Action with Iran (“JCPOA”). The following day, as certain re-imposed sanctions took effect, the President…
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Davis Polk Financial Services Regulatory Reform Tool—Summer Beach Read Edition
Posted in Administrative Law, Anti-Money Laundering, Bank Capital, Bank Regulation, BCFP, CFTC, Community Reinvestment Act, Cost-Benefit Analysis, Dodd-Frank, Economic Sanctions, FDIC, Federal Reserve, FSOC, Legislation, Liquidity, OCC, OFAC, Stress Testing, Swap Regulation, TLAC, U.S. Basel III, U.S. Congress, Volcker Rule
Financial services regulatory reform in 2018 continues to evolve. For those of you who have been thinking you might catch up over the summer lull, here is the summer beach read edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas,…
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OFAC Announces Regulations and Guidance Implementing Withdrawal from the JCPOA
Posted in Economic Sanctions, OFAC
On June 27, 2018, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced amendments to the Iranian Transactions and Sanctions Regulations (“ITSR”), 31 C.F.R. part 560, and published updated answers to frequently asked questions (“FAQs”) to further implement President Trump’s May 8,…
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