On December 20, 2022, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it was amending its regulations in multiple sanctions programs to reflect that the property and interests in property...more
As noted in our prior alerts (concerning OFAC’s September 9, 2022 preliminary guidance and October 31, 2022 follow-on FAQ clarifying the applicability of the impending price cap policy) the U.S. Department of the Treasury’s...more
On October 31, 2022 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published FAQ 1094, which addresses the question of whether crude oil of Russian Federation origin that is loaded onto a vessel...more
On September 20th, 2022, the Securities and Exchange Commission (“Commission”) entered a settled order (“Order”) against the wealth management arm of a global financial services firm (“Firm”) for its failure to protect...more
On October 3, 2022, in Commodities & Minerals Enterprise Ltd. v. CVG Ferrominera Orinoco, C. A., the Second Circuit Court of Appeals resolved a novel question of first impression in favor of petitioner Commodities & Minerals...more
On September 27, 2022, the Securities and Exchange Commission (“Commission”) entered into a series of settled orders (“Orders”) against 15 broker-dealers and one affiliated investment adviser for widespread failures by the...more
10/4/2022
/ Broker-Dealer ,
Compliance ,
Electronic Communications ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Penalties ,
Policies and Procedures ,
Recordkeeping Requirements ,
Securities ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934
On September 9, 2022 OFAC issued a preliminary guidance on the Implementation of a Maritime Services Policy and Related Price Exception for Seaborne Russian Oil in furtherance of a policy established by a coalition of...more
The United States sanctions regime is a complex and ever-changing regulatory space. The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) maintains sanctions lists which are updated in real-time—not on...more
On June 15, 2022, the Securities and Exchange Commission (“SEC”) filed a complaint against California-based broker-dealer Western International Securities, Inc. (“Western”) alleging violations of Regulation Best Interest...more
6/29/2022
/ Best Interest Standard ,
Broker-Dealer ,
Enforcement Actions ,
Fiduciary Duty ,
Financial Services Industry ,
Investment ,
Investment Adviser ,
Investment Management ,
Regulation Best Interest ,
Regulation BI ,
Retail Installment Sales Contracts ,
Retail Investors ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Transactions ,
Securities Violations ,
Standard of Conduct