Executive Order

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On January 28, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned Petroleos de Venezuela S.A. (“PdVSA”), Venezuela’s state-owned oil company, pursuant to Executive Order (“E.O.”) 13850 for operating in the oil sector of the Venezuelan economy, following a determination by the Secretary…
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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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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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There are distinct, but subtle, shifts in tone in the FSOC’s 2017 Annual Report, especially when compared to previous annual reports and read together with three recent Treasury reports on financial regulatory reform, each of which touches on the role of the FSOC.[1] Taken as a whole, the 2017…
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The U.S. Treasury’s new Capital Markets Report recommends additional administrative requirements for regulatory actions by the SEC and the CFTC (the “Agencies”).  If adopted, the process by which the Agencies issue new regulations and guidance may be more transparent and subjected to more rigorous cost-benefit analysis.  Rulemaking and issuing no-action…
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This evening, Treasury Secretary Mnuchin published the long-awaited report on proposals to existing banking regulations (press release here), which is the first of what will be several reports, in accordance with President Trump’s February 3 Executive Order on Core Principles for Regulating the U.S. Financial System. The report…
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Few have embraced President Trump’s Executive Order on Core Principles for Regulating the U.S. Financial System as swiftly and decisively as CFTC Acting Chair Christopher Giancarlo. His Project KISS – Keep It Simple, Stupid, announced within weeks of the Executive Order, is an agency-wide internal review focused on simplifying…
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There is no shortage of ideas from the financial sector on how to rebalance financial sector regulation judging by the many reports, white papers and letters that have been sent to Treasury Secretary Mnuchin and his staff. We thought our readers, and perhaps the Treasury staff who must be burning…
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President Trump issued a Presidential Memorandum last Friday, April 21, which directed the Treasury Secretary to conduct a review of the Orderly Liquidation Authority (OLA). OLA was established by Title II of the Dodd-Frank Act. Its potential repeal, with or without a new Chapter 14 (or subchapter V of Chapter…
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Yesterday afternoon, President Trump issued a memorandum directing the DOL to review the fiduciary rule it released last April that expanded the definition of an investment advice fiduciary with respect to retirement investors. The fiduciary rule became effective on June 7, 2016, but the requirements under the rule would not…
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