The U.S. Treasury Department Office of Foreign Assets Control ("OFAC") sanctioned over two dozen individuals and entities for allegedly transferring over a billion dollars and euros to the Islamic Revolutionary Guard Corps ("IRGC") and Iran's Ministry of Defense and Armed Forces Logistics ("MODAFL"). The designated persons include a network of Iran-, United Arab Emirates- and Turkey-based front companies. Pursuant to Executive Order 13224, OFAC also designated MODAFL and an Iranian bank for their assistance to the IRGC-Qods Force. As a result of OFAC's action, all property and interests in the

The Office of the Comptroller of the Currency ("OCC") reminded all national banks and federal savings associations that they are forbidden from disclosing nonpublic OCC information ( e.g., investigatory files) without approval. The OCC said that any improper disclosure or use of nonpublic OCC information without the explicit permission of the OCC may incur criminal penalties pursuant to federal law.

NFA reminded members of recently amended (i) NFA Bylaw 301 and NFA Compliance Rule 2-24, and (ii) Interpretive Notice implementing swaps proficiency requirements. As previously covered, the amendments require that any individual engaged in swaps activities (whether registered as a swap firm intermediary or swap-associated person ("AP")), or simply acting as an AP of a swap dealer, satisfies NFA's Swaps Proficiency Requirements. NFA stated that the swaps proficiency requirements will become effective on January 31, 2020. The Interpretive Notice, titled NFA Bylaw 301 and Compliance Rule 2-24

The CFTC passed an interim final rule to allow uncleared swaps to retain "legacy status" under the CFTC margin requirements in the event of a "no-deal" Brexit. The vote was unanimous. According to statements at the open meeting, the rule is intended to be consistent with a recent interim final rule adopted by the prudential regulators. CFTC Commissioner Dan Berkovitz, who supported the action, noted that "these actions are all taken pursuant to, and are consistent with, the existing regulations and guidance in place at the CFTC governing cross-border activities." CFTC Commissioner Brian

The European Securities and Markets Authority ("ESMA") provided additional guidance on the impact of a no-deal Brexit on the Markets in Financial Instruments (MiFIR) trading obligations for shares in the event of no equivalence decision for the UK. ESMA recognized that a "no-deal" Brexit scenario is creating considerable uncertainty amongst market participants. The additional guidance explains (i) the distinction in the nomenclature between EU27 shares and GB shares and (ii) which GB shares will be deemed to have their main pool of liquidity in the UK and which will be deemed to be in the EU27