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Overview

On March 12, 2026, the U.S. Commodity Futures Trading Commission (CFTC) took formal steps toward establishing additional regulations for prediction markets. The agency issued an Advanced Notice of Proposed Rulemaking (ANPRM) soliciting public input on potential new rules, and separately, released staff guidance outlining its views on how existing rules apply to prediction market platforms currently in operation. These developments signal a significant shift in the regulatory landscape for an industry that has grown rapidly over the past year.

Continue Reading CFTC Takes Additional Steps Toward Prediction Market Regulation: What You Need to Know

What You Need To Know

  • The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued six new general licenses, and updated a seventh that allow for many activities related to: the export of Venezuelan oil and petrochemical products from Venezuela; the exploration, development, and production of oil, gas, and petrochemical products in Venezuela; the generation, transmission, storage, or distribution of electricity in Venezuela; the export to Venezuela of U.S.-origin diluents; negotiating for investment in the oil, gas, petrochemical, and electricity sectors in Venezuela; and the export of Venezuelan gold.
  • The new general licenses contain a number of significant conditions, including in GLs 46B and 51, a limitation to the activities of “established U.S. entities,” and in GLs 46B, 47, 48A, 50A, and 51, limits on counterparties and operators, a prohibition on the involvement of entities with specific relationships to China, Cuba, Iran, North Korea, and Russia, or of sanctioned vessels, and contractual requirements to use U.S. law and U.S. dispute resolution mechanisms.
  • This regulatory space is fast moving, with multiple changes occurring over a short time period, and any plan to rely on these general licenses and authorizations should include transaction-by-transaction assessment, along with monitoring by compliance and legal functions.
Continue Reading Eight Takeaways After Seven Weeks of OFAC’s Six — wait, Seven — New and Updated General Licenses for Venezuela

What You Need to Know

Key Takeaway #1: FinCEN will no longer require covered financial institutions to identify and verify beneficial owners of legal entity customers each time the customer opens a new account at the institution, but rather only in certain circumstances.

Key Takeaway #2: FinCEN will instead require certain financial institutions to identify and verify the identities of such beneficial owners: (1) when a legal entity customer first opens an account with a covered financial institution; (2) when the covered financial institution has knowledge of facts that would reasonably call into question the reliability of beneficial ownership information previously obtained about the legal entity customer; and (3) as needed based on a covered financial institution’s risk-based procedures for conducting ongoing customer due diligence. For (3), covered financial institutions may rely on the customer’s certification that its beneficial ownership information has not changed, unless there is reason to question this.

Key Takeaway #3: The exceptive relief is the latest instance of recent efforts by the Department of the Treasury to modernize and eliminate unnecessary burdens associated with BSA rules; covered financial institutions are likely to welcome the relief.

Continue Reading FinCEN Grants Exceptive Relief to Streamline Beneficial Ownership Verification Requirements for Financial Institutions

Key Takeaways:

  1. The Russian Federation, Bolivia and the British Virgin Islands (“BVI”) have been added to the EU list of third countries deemed high risk for AML/CTF purposes.
  2. The EU has removed Burkina Faso, Mali, Mozambique, Nigeria, South Africa, and Tanzania from this list.
  3. The EU’s position redefines the risk landscape for entities with exposure to Russian, Bolivian, and BVI organisations or individuals, and consequently increases commercial pressure on EU/Russian relationships with extensive global sanctions already imposed due to the ongoing Russia/Ukraine conflict.
Continue Reading EU Amendments to List of High-Risk AML/CTF Countries

The UK’s Office of Financial Sanctions Implementation (OFSI) has launched a call for evidence concerning the “ownership and control” test within UK financial sanctions. The call for evidence, running until 11:59 p.m. on 13 April 2026, seeks stakeholder views on the challenges and implementation of the “control” limb, with particular focus on its hypothetical element.

Continue Reading UK Government Seeks Evidence on Ownership and Control in Financial Sanctions Regulations

On January 14, 2026, State Senator Zellnor Myrie proposed legislation in the New York State Senate that would amend New York law to make it a criminal offense to operate a virtual currency business in New York without the proper license. By introducing the possibility of criminal penalties, Senate Bill S. 8901, the Cryptocurrency Regulation Yields Protections, Trust, and Oversight Act (CRYPTO Act), would mark a significant regulatory shift in the state’s oversight of virtual currency businesses, given New York’s prominence in virtual currency regulation in the U.S.

Continue Reading Proposed NY Legislation May Mean Potential Criminal Charges for Unlicensed Crypto Firms

Seeking to protect their investments in the face of increased liability management exercises, lenders began signing “cooperation agreements,” which required the lenders to cooperate when negotiating to restructure existing debt or provide new debt to their shared borrower. These cooperation agreements protect lenders from “creditor-on-creditor violence” — when one lender (or a subset of lenders) renegotiates with a borrower to the benefit of the negotiating lender and the detriment of the others.

In November 2025, Optimum Communications, Inc. (f/k/a Altice) and CSC Holdings, LLC (together, Optimum) filed a federal antitrust lawsuit against its lenders — Apollo, Ares, GoldenTree, Loomis, Oaktree, and PGIM (collectively, the Cooperative) — challenging their cooperation agreement as an unlawful cartel. In the complaint, Optimum alleges two antitrust theories: (i) the Cooperation Agreement constituted a group boycott of Optimum because the Cooperative members agreed not to individually work with Optimum to restructure debt absent supermajority approval from the Cooperative, and (ii) the Cooperation Agreement constituted an unlawful price-fixing scheme by requiring the Cooperative’s steering committee to negotiate with Optimum exclusively, rather than allow Optimum to negotiate individual discounts with individual lenders. Optimum alleges that because the Cooperative controls approximately 88% of the entire leveraged finance market and 99% of Optimum’s outstanding debt, the Cooperation Agreement has made it incredibly difficult for Optimum to restructure its debt.

Continue Reading Optimum’s Shot Across the Bow: An Antitrust Challenge to Cooperation Agreements

On December 19, 2025, New York Governor Kathy Hochul vetoed a bill that would have amended the New York LLC Transparency Act (“New York Act”) to include beneficial ownership information (“BOI”) reporting requirements for all non-U.S. and U.S. limited liability companies (“LLCs”) registered to do business in New York State (“New York”).

The Governor’s veto means that the New York Act willonly require disclosure of BOI only for non-U.S. LLCs registered to do in business in New York that do not otherwise qualify for any of the exemptions in the New York Act, and only with respect to non-U.S. beneficial owners.

Continue Reading Governor’s Veto Limits Scope of New York LLC Transparency Act to Foreign LLCs Registered in New York

In an effort to improve market efficiency and to speed settlement, the Loan Syndications and Trading Association (the “LSTA”) is proposing amendments to its trading documents in order to address concerns that market participants are increasingly failing to make timely payment of the “Purchase Price” with respect to their bank loan trade settlements. Although typically only one or two days late, such failures, on a large scale, can prove to be quite costly to loan sellers and disruptive to the market as a whole. The proposal would introduce language into the LSTA Standard Terms and Conditions for its suite of trade confirmations (the “Standard Terms”) that would require tardy loan buyers to pay a “Late Payment Fee.”

Continue Reading LSTA Proposes Introduction of Late Payment Fees in Loan Trade Transactions

Yesterday, FinCEN announced an ongoing enforcement initiative against more than 100 money services businesses (“MSBs”) operating along the Southwest U.S. border. FinCEN says that it reviewed over one million currency transaction reports (“CTRs”) and 87,000 suspicious activity reports (“SARs”) using new data processing techniques to identify potential Bank Secrecy Act (“BSA”) compliance concerns with MSBs there. The agency says this resulted in six FinCEN Notices of Investigation, “dozens” of referrals to the IRS, and 50 compliance outreach letters. An accompanying video from Treasury Secretary Scott Bessent suggests that the initiative is intended to “stop terrorist cartels, drug traffickers, and human smugglers” and to “root out potential cartel-related money laundering from the U.S. financial system.”

Continue Reading FinCEN Announces Enforcement Initiative for MSBs Along the Southwest Border