The U.S. Treasury Department ("Treasury") Office of Foreign Assets Control ("OFAC") designated a Russia-based bank for materially assisting Petróleos de Venezuela S.A. ("PdVSA"), which OFAC sanctioned in January 2019 and described as a "vehicle for corruption, embezzlement, and money laundering." OFAC stated that, pursuant to Executive Order 13850, Evrofinance Mosnarbank ("Evrofinance") "materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the sanctioned entity." According to OFAC, assets of Evrofinance grew

The U.S. District Court for the District of Columbia entered a Consent Order ("Order") against a foreign trading platform and its CEO (collectively, the "Defendants") for unlawful bitcoin-related transactions with U.S. customers. The Order resulted from a September 2018 Complaint filed by the CFTC. According to the Order, the Defendants (i) illegally offered commodity transactions that were in the form of "contracts for difference" involving gold and crude oil, (ii) neglected to register as a futures commission merchant with the CFTC and (iii) failed to satisfy their supervisory

The NFA reminded members that April 1, 2019 is the effective date for amendments to the Interpretive Notice relating to information systems security programs ("ISSP"). As previously covered, the amendments concern cybersecurity training obligations, the approval of a firm's ISSP, and cybersecurity breach notifications.

In connection with the Share Class Selection Disclosure Initiative ("SCSDI"), the SEC settled charges against 79 investment advisers, who will collectively return over $125 million to clients. The majority of the funds will go to retail investors. The SEC Orders found that the investment advisers placed clients in higher-cost mutual fund share classes that charged ICA Rule 12b-1 fees ("12b-1 fees") when a lower-cost share class was available without adequately disclosing that the higher-cost class was being selected. According to the Orders, the 12b-1 fees were paid to the investment advisers

In a "dialogue" held at Fordham University, SEC Chair Jay Clayton and Director of Division of Trading and Markets Brett Redfearn discussed (i) improving liquidity for thinly traded securities, (ii) revising SEA Rule 15c2-11, ("Initiation or resumption of quotations without specific information"), as well as the rules applicable to the execution of trades in penny stocks for retail investors and (iii) the deficiencies in "core" market data as compared to proprietary data. On market data, the regulators expressed concern about the current "two-tiered" system. The "core" tier is the consolidated