The U.S. Treasury Department ("Treasury") Office of Foreign Assets Control ("OFAC") replaced two general licenses under Executive Orders 13808 and 13850 related to sanctions imposed "with respect to the situation in Venezuela." OFAC also revised three FAQs ( see here, here and here) that explain the two general licenses. Both of the revised general licenses make clear that, in most circumstances, U.S. persons are not authorized to purchase or invest in, or to facilitate the purchase of or investment in, certain bonds or securities, other than to make purchases or investments that are

In remarks at the University of Missouri School of Law, SEC Commissioner Hester Peirce described the difficulty in applying securities laws in general, and the Howey test in particular, to virtual currency and initial coin offerings. Ms. Peirce expressed concern that the SEC's application of the Howey test will be "overly broad," stating that token offerings do not always resemble traditional securities offerings. Some cryptocurrency projects may be unable to proceed because they cannot comply with applicable securities regulations, she said. In addition, she encouraged a "delay in drawing

The proposal of the Federal Reserve Board, FDIC and Office of the Comptroller of the Currency, simplifying capital requirements for qualifying community banking organizations that opt into a community bank leverage ratio framework ("CBLR"), was published in the Federal Register. Comments must be submitted by April 9, 2019. As previously covered, the proposed CBLR framework is a "simple alternative methodology to measure capital adequacy" and would provide substantial regulatory relief to smaller banking organizations, consistent with Section 201 of the Economic Growth, Regulatory Relief, and

A proposal by the FDIC, the Federal Reserve Board, the Office of the Comptroller of the Currency, the SEC and the CFTC to exclude certain community banks from the Volcker Rule was published in the Federal Register. Comments must be submitted by March 11, 2019. As previously covered, pursuant to Section 203 of the Economic Growth, Regulatory Relief and Consumer Protection Act ("EGRRCPA"), the proposal would exclude a community bank from the restrictions of the Volcker Rule if both of the following conditions are met: (i) it has total consolidated assets equal to or less than $10 billion, and

In a letter to Federal Reserve Board ("FRB") Chair Jerome Powell, Senator Elizabeth Warren (D-MA) raised questions about the FRB's approval process for bank mergers and acquisitions ("M&A"). Ms. Warren first wrote to the FRB about its review of bank mergers in April 2018. Ms. Warren voiced concern about FRB's high rates of M&A application approvals. She also expressed concern about the FRB’s practice of allowing consultations between FRB staff and M&A applicants, which raise "questions about transparency and fairness." Ms. Warren's letter was released after SunTrust Banks, Inc. and BB&T