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The U.S. banking agencies have proposed allowing custodial banking organizations to exclude certain central bank deposits from the calculation of total leverage exposure, the denominator ...
In separate statements on April 17, 2019 coinciding with the anniversary of the Bay of Pigs invasion, U.S. Secretary of State Mike Pompeo and National Security Adviser John Bolton announc...
The Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) recently publicly announced that it had imposed a $1 million civil monetary penalty against a...
Yesterday, the FDIC issued and invited comments on a proposal to amend and restate their 165(d) Rule, issued jointly with the Federal Reserve, which implements the resolution planning req...
There is now a serious effort underway by the usually divided Congress to find a way for the growing cannabis sector to enter the mainstream financial sector. This visual memorandum updat...
Tom Baxter of Sullivan & Cromwell LLP, and formerly the General Counsel of the Federal Reserve Bank of New York, has written an important article titled “The Rise of Risk Management in ...
Blockchain technology continues to be a lively topic of conversation in legal, business and technology circles. This memo focuses on several key topics for companies considering whether a...
Last week, the SEC staff published new detailed guidance on its views of when a digital asset may be considered a security, in the form of two documents: a guidance “framework” issue...
Today, the Federal Reserve issued and invited comments on a proposal to amend and restate their 165(d) Rule, which implements the resolution planning requirements of Section 165(d) of the...
On April 8, 2019, the U.S. State Department announced its intent to designate Iran’s Islamic Revolutionary Guard Corps (“IRGC”) as a Foreign Terrorist Organization (“FTO”) under...