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James Treanor Commentary by James Treanor

The U.S. Treasury Department Office of Foreign Assets Control ("OFAC") sanctioned seven individuals and 23 entities in a corruption scheme designed to exploit Venezuela's currency exchange practices. A private aircraft was also identified as blocked property. Pursuant to Executive Order 13850, OFAC targeted individuals, including two former Venezuelan National Treasurers, for a scheme that allegedly generated over $2.4 billion in corrupt proceeds since 2008. The illicit profits were invested in assets including aircraft, yachts, horses and watches. As a result of OFAC's action, all properties

In a Bulletin, the Office of the Comptroller of the Currency reminded banks of annual adjustments, which took effect on January 1, 2019, amending the asset-size thresholds used to define "small bank," "small savings association," "intermediate small bank" and "intermediate small savings association" under the Community Reinvestment Act.

The NFA amended an Interpretive Notice (the "Notice") on Information Systems Security Program ("ISSP") requirements. The amendments address cybersecurity training obligations, approval of a firm's ISSP, and cybersecurity breach notification. The new amendments become effective on April 1, 2019. The original Notice, which became effective on March 1, 2016, required NFA member firms - including futures commission merchants, introducing brokers, commodity pool operators and commodity trading advisors - to adopt a written ISSP to address the risk of attacks on, and unauthorized access to, a member

The MSRB requested applications for five positions (three public representatives and two regulated representatives) on its 21-member governing board. Applications may be submitted until February 15, 2019.