FINRA Proposes Rules Targeting Firms With History of Misconduct

By Robin M. Bergen, Carl F. Emigholz, Phillip L. Hurst & Samuel H. Chang on May 13, 2019

On May 2, 2019, FINRA proposed new rules to designate “high-risk” firms and strengthen its ability to impose additional obligations on those firms.[1] Proposed Rule 4111 would authorize FINRA to designate “Restricted Firms” based on the number of event disclosures made by the firm and its registered persons. Restricted Firms would be subject to limitations on their operations and could be required to maintain restricted deposits that could only be withdrawn with FINRA’s consent.…

Cleary International Trade and Sanctions Watch

Sanctions Tighten on Iranian Metals Sectors

By Paul Marquardt & Samuel H. Chang on May 10, 2019

On May 8, 2019, President Trump issued a new Executive Order expanding secondary sanctions against the iron, steel, aluminum, and copper sectors of Iran. The Executive Order provides authority to impose sanctions on foreign persons who operate in the covered metals sectors or who facilitate significant transactions in connection with those sectors. Unlike direct sanctions (which have long prohibited unlicensed dealings with Iran with a connection to U.S. jurisdiction), secondary sanctions threaten the imposition of…

Cleary International Trade and Sanctions Watch

Russia Sanctions Bill Reintroduced by Bipartisan Group of Senators

By Paul Marquardt & Samuel H. Chang on March 4, 2019

On February 13, 2019, a bipartisan group of senators introduced a draft bill that, if adopted, would significantly strengthen sanctions relating to the Russian Federation. Introduced as the “Defending American Security from Kremlin Aggression Act of 2019” (“DASKA”), the wide-ranging bill covers a number of subjects, in particular a range of new cybersecurity provisions. This note focuses on the sanctions provisions, which would:…

Cleary Cybersecurity and Privacy Watch

OFAC Lists Digital Currency Addresses for First Time, Releases New Guidance

By Paul Marquardt, Katherine Mooney Carroll, Alexis Collins, Chinyelu Lee & Samuel H. Chang on December 5, 2018

On November 28, 2018, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) identified for the first time digital currency addresses associated with sanctioned persons. The newly sanctioned individuals, Iran-based Ali Khorashadizadeh and Mohammad Ghorbaniyan, were accused of converting digital currency payments into Iranian rial as part of a widespread ransomware scheme. Since 2015, the ransomware scheme (known as “SamSam”) has infected the data networks of corporations, hospitals, universities, and government agencies. According…

Cleary International Trade and Sanctions Watch

OFAC Lists Digital Currency Addresses for First Time, Releases New Guidance

By Paul Marquardt, Katherine Mooney Carroll, Alexis Collins, Chinyelu Lee & Samuel H. Chang on December 5, 2018

Samuel H. Chang

FINRA Proposes Rules Targeting Firms With History of Misconduct

Sanctions Tighten on Iranian Metals Sectors

Russia Sanctions Bill Reintroduced by Bipartisan Group of Senators

OFAC Lists Digital Currency Addresses for First Time, Releases New Guidance

OFAC Lists Digital Currency Addresses for First Time, Releases New Guidance

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