Based on the information and suggestions that the CFTC received as part of its Project KISS, the CFTC proposed simplifying regulatory obligations for CPOs and CTAs by codifying staff advisories and no-action letter relief in the CFTC Part 4 regulations. The CFTC proposed: (i) registration exemptions for CPOs that solicit and/or accept funds from only non-U.S. persons for participation in offshore commodity pools, (ii) allowing the U.S.-based CPO of an offshore commodity pool with U.S. participants to maintain the commodity pool's original books and records in the offshore location of the pool

A multinational bank agreed to pay approximately $5 million to settle a U.S. Department of the Treasury ("Treasury") Office of Foreign Assets Control ("OFAC") investigation to settle charges concerning apparent violations of the Cuban Assets Control Regulations, the Iranian Transactions and Sanctions Regulations, and the Weapons of Mass Destruction Proliferators Sanctions Regulations. OFAC stated that JPMorgan Chase Bank, N.A. ("JPMC") self-disclosed the violations. In so doing, OFAC stated that it considered the violations to constitute a "non-egregious" case. Separately, OFAC issued a

In a new advisory, the U.S. Treasury Department's Financial Crimes Enforcement Network ("FinCEN") alerted financial institutions to the risk that proceeds of political corruption from Nicaragua may enter the U.S. financial system.

The SEC updated its Compliance and Disclosure Interpretations (C&DIs) to remind issuers that the revised disclosure requirements as to shareholders' equity go into effect on November 5, 2018. SEC staff stated that it would not object to changes in shareholders' equity made by the filer if the changes are included in Form 10-Q for the first quarter that begins after the effective date of the amendments (see Question 105.09).

At its September Board meeting, FINRA approved significant revisions to margin requirements for Covered Agency TBA (to-be-announced) Transactions. The revisions would, pending approval by the SEC: (i) eliminate the 2 percent maintenance margin requirement and (ii) allow firms to take capital charges in lieu of collecting margin, within certain limits. In addition, FINRA approved the publication of a Regulatory Notice to seek comments on amendments to Rule 4210 to "clarify and incorporate . . . current interpretations" regarding "when-issued" and extended settlement transactions. In other