OFAC Updates Counter-Terrorism Sanctions

OFAC today adopted a final rule that amends the Global Terrorism Sanctions Regulations to implement a 2019 executive order and make several minor technical changes.

Basel Crafts Stringent New Regime for Crypto Exposures

As promised, the Basel Committee today tried again to craft a global prudential regime for bank crypto exposures.  We will shortly provide clients with an in-depth analysis of the new consultation, which replaces a controversial first round (see FSM Report CRYPTO19) with one that continues add-on capital requirements for higher-risk digital assets (now redefined for stablecoins).

FSB Frets About Commodity, Resilience Risk

The FSB’s plenary today is far more pessimistic about both macroeconomic and financial conditions than it was just a month ago.  Although it then worried about commodity-market volatility, these concerns now are heightened by large margin calls, “undetected” leverage, and concentrated exposures.

CFPB Pledges Guidance on Wage Access Products

The CFPB today terminated the Sandbox Approval Order for Payactiv, an earned wage access company, removing an exemption for some of the company’s products from liability under the Truth in Lending Act.  Payactiv requested the termination in order to make changes to its fee model, as changes to its products would require modifications to the order.

Daily063022.pdf