The SEC proposed establishing "risk mitigation" requirements applicable to security-based swap dealers ("SBSDs"), including portfolio reconciliation and compression, and swap trading relationship documentation. In a proposal, the SEC noted that it "attempted to harmonize [its] proposal with the existing CFTC rules wherever possible." The proposing release provides explanations of the relevant differences between the rules. Proposed Rule 15Fi-3 would require SBSDs to engage in portfolio reconciliations. The rule is analogous to CFTC Rule 23.502. Proposed Rule 15Fi-4 would require SBSDs to

The National Futures Association ("NFA") reminded certain futures commission merchant ("FCM") and retail foreign exchange dealers ("RFED") that regulatory filings will be affected due to the Christmas and New Year's Day holidays. The NFA stated that any information filed after its due date by FCMs or RFEDs must be accompanied by a fee for every single business day that it is late.

A global investment banking and brokerage firm agreed to settle FINRA charges of selling IPO shares to "restricted persons." According to the Letter of Acceptance, Waiver, and Consent, the firm violated FINRA Rule 5130 by making over 1,400 prohibited sales of IPO shares in 325 offerings to 149 customer accounts where restricted persons had a "beneficial interest." FINRA stated that the firm allowed the "associated persons of broker-dealers and/or immediate family members of . . . financial advisors" ("FAs"), restricted persons normally prohibited from buying IPO shares, to receive shares due

A Missouri-based industrial equipment and services company agreed to settle U.S. Treasury Department Office of Foreign Assets Control ("OFAC") charges for violating Belarus Sanctions Regulations. According to OFAC, Zoltek Companies, Inc. ("Zoltek") submitted a voluntary self-disclosure, after which OFAC initiated an investigation into Zoltek's activities. OFAC's review of Zoltek's submissions identified apparent violations of the Belarus Sanctions Regulations, including dealing in the property of a "blocked person identified on OFAC's List of Specially Designated Nationals and Blocked Persons

The CFTC issued three related no-action letters that, taken together, permit Eurex Clearing AG ("Eurex"), a registered derivatives clearing organization ("DCO") located in Europe, to clear swap transactions on behalf of U.S. customers of futures commission merchants ("FCMs"). In CFTC Letter 18-30, the CFTC Division of Clearing and Risk ("DCR") confirmed that Eurex demonstrated its ability to comply with the straight-through processing requirements of CFTC Rule 39.12(b)(7). As a result, Eurex can begin "clearing and settling transactions on behalf of U.S. persons that are clearing members, U.S