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In a new advisory, the Financial Crimes Enforcement Network ("FinCEN") alerted financial institutions as to ways to help better detect and report the Iranian regime's efforts to evade U.S. sanctions. FinCEN’s advisory includes specific red flags and deceptive practices that may be employed by Iran. This notification comes just weeks ahead of the full re-imposition of U.S. sanctions (November 5, 2018), which were previously lifted under the Iran nuclear deal, also called the Joint Comprehensive Plan of Action (JCPOA).

The SEC outlined how it intends to adapt to evolving financial markets and technologies in a new report, "Strategic Plan for 2018-2022." The report, which is required by law, offers three key goals that the SEC will seek to address: the long-term interests of Main Street investors; significant developments and trends in capital markets; and improvements to its human capital management program.

The National Futures Association ("NFA") amended its Bylaw 1303 governing a Member's failure to timely pay certain fees, which is regarded as a default and deemed a request to withdraw from NFA membership. Effective on October 31, 2018, NFA Bylaw 1301 will (i) include fees for filing late reports under certain regulations and (ii) make the time period when the default and deemed request to withdraw occurs consistent for all late payments.

Steven Lofchie Commentary by Steven Lofchie

A floor broker who traded options at the Chicago Board of Trade agreed to settle CFTC charges that he defrauded his employer by (i) falsely inflating the value and profitability of options positions and (ii) misrepresenting the number of options and risk associated with his position. According to the Consent Order, the floor broker's activity resulted in his employer, proprietary trading firm Rock Capital Markets, LLC ("Rock Capital"), paying him $285,000 in draws based on false reports of his trading positions and profitability. The floor broker's misconduct resulted in losses of over $13