As mid-year 2018 approaches, we have updated our brief deck summarizing the leadership and staffing changes among federal financial regulators, including announced nominations and resignations and expiring terms.  The first slide summaries the state of play for the principals, and the later slides provide a deeper dive on an agency-by-agency … Read More

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 … Read More

As expected, the DOL has officially delayed the applicability date of the full requirements of the Best Interest Contract (BIC) Exemption, Principal Transactions Exemption and PTE 84-24 by 18 months, from January 1, 2018 to July 1, 2019.  Our post from earlier this year described which requirements of these exemptions … Read More

The Treasury Department’s recent report on capital markets regulation includes a robust discussion of equity market structure issues.  The report does not break new ground or raise issues that have not been debated previously at length, including by the SEC’s Equity Market Structure Advisory Committee (“EMSAC”).  That said, the report … Read More

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 … Read More

As a follow-up to our prior post, the OMB has approved the DOL’s proposal to delay the full applicability date of the exemptions related to the fiduciary rule and shortly thereafter the DOL has issued a proposed rule that would further delay the applicability date of the currently-delayed requirements … Read More

On August 2, 2017, President Trump signed into law the Countering America’s Adversaries Through Sanctions Act of 2017 (the “Act”).  The measure, which was passed by substantial bipartisan majorities in the House and in the Senate, codifies certain sanctions previously imposed by Executive Order (“E.O.”), provides for new sanctions with … Read More

The Trump Administration submitted its second certification to Congress regarding Iranian compliance with the Joint Comprehensive Plan of Action (the “JCPOA”) on July 17, 2017.  Like the Administration’s first certification made in April 2017, it continued to focus more on Iran’s “malign activities” outside the nuclear context than on Iran’s … Read More

Jay Clayton’s first public speech on Wednesday as Chairman of the SEC foretold few, if any, sweeping regulatory changes at the Commission. His remarks, delivered to the Economic Club of New York, outlined eight principles that will guide his approach to regulation, which included support for the agency’s historic … Read More

2017 Enforcement Trends: Mid-Year Review

Please join us for a discussion on some of this year’s key enforcement trends and developments in U.S. Sanctions and Anti-Money Laundering.

  • Trends and expectations of the new Administration
  • Notable developments in U.S. sanctions programs
  • Review of AML initiatives
  • Recent enforcement actions

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