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FinCEN Adds Virtual Currency to High-End Real Estate Reporting Regime

USA - November 20 2018 A perfect storm for AML risk can arise from (i) the use of legal entities to conceal ownership, (ii) the limited application of anti-money laundering...

Thomas J. Delaney, David L. Beam, Alex C. Lakatos.


CFTC Permanently Sets the Swap Dealer De Minimis Threshold at $8 Billion and Determines Not to Adopt Other Proposed Changes

USA - November 16 2018 On November 5, 2018, the US Commodity Futures Trading Commission ("CFTC") finalized an amendment to the de minimis exception within the swap dealer...

David R. Sahr, J. Paul Forrester, Curtis A. Doty.


US Banking Agencies Propose Changes to Calculation of Derivative Contract Exposures under Regulatory Capital Rules

USA - November 9 2018 On October 30, 2018, the Federal Reserve Board, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation issued a...

J. Paul Forrester, Donald S. Waack, Curtis A. Doty.


Court Finds That Virtual Currency Is a CommodityFor the Time Being

USA - November 5 2018 On September 26, 2018, a US federal court found that virtual currency constitutes a class of items that are commodities under the Commodity Exchange...

Jerome J. Roche, J. Paul Forrester, David L. Beam.


SEC Brings First Enforcement Action Under the Identity Theft Red Flags Rule

USA - October 23 2018 On September 26, 2018, the US Securities and Exchange Commission ("SEC") brought and settled charges against a registered broker-dealerinvestment...

Jeffrey P. Taft, Adam D. Kanter.