The Trump administration designated Iran's Islamic Revolutionary Guard Corps ("IRGC") as a Foreign Terrorist Organization ("FTO"), making it the first time that the United States has designated part of another government as an FTO. The Trump administration asserted that the designation will increase financial pressure on the regime and deprive it of necessary resources to fund terrorist activities. The action puts businesses and other governments "on notice" with respect to the nature of the IRGC, which "operates front companies and institutions around the world to fund terror." The action

FINRA proposed to extend the pilot period relating to FINRA Rule 6121.02 ("Market-Wide Circuit Breakers in NMS Stocks") until October 18, 2019. FINRA filed the proposal for immediate effectiveness and noted that it will file a separate proposal to operate Rule 6121.02 on a permanent basis.

The SEC corrected a rule document published in the Federal Register concerning the final amendments to Regulation S-K and related rules and forms. The correction referred to a section number in a table text entry. As previously covered, the rule changes - which are intended to reduce disclosure burdens on registrants - will generally go into effect on May 2, 2019.

The CFTC Division of Swap Dealer and Intermediary Oversight granted a non-U.S. financial institution temporary no-action relief from the requirement to be registered as an introducing broker ("IB"). The relief was granted in connection with the transfer of certain IB activities from the United Kingdom (where the institution currently conducts IB activities under a CFTC Part 30.10 Order) to another country (where the institution is not yet eligible to take advantage of the relief). The IB would then be permitted under CFTC Rule 3.10(c)(4) to engage in limited U.S. futures and options

Late last week, a bipartisan team of lawmakers reintroduced the Strengthening the Tenth Amendment Through Entrusting States Act (the "STATES Act") in the Senate and House of Representatives. The STATES Act would amend the Controlled Substances Act ("CSA") to restrict federal enforcement against state-legal cannabis activity. In particular, the STATES Act would prevent the application of the CSA to persons complying with state law with respect to the manufacture, production, possession, distribution, dispensation, administration or delivery of cannabis. Additionally, the STATES Act would