Implications of Outbound Investment Penalty

Consider writing about:

An Oct. 7 announcement by the U.S. Department of the Treasury regarding the first civil penalty the department has levied under the Outbound Investment Security Program (OISP); what to know about the OISP’s focus and its history under the Biden and Trump administrations; key requirements set by the OISP; alleged OISP violations that led to the penalty announced by the Treasury Department; how other entities can avoid running afoul of the OISP.

Related information:

https://home.treasury.gov/news/press-releases/sb0652

Debanking Debriefing: What to Make of Recent OCC Report

Consider writing about:

A report released this month by the Office of the Comptroller of the Currency regarding purported “debanking” actions by nine major banks; what “debanking” consists of (generally speaking or in these specific instances), and how debanking-related allegations are treated under the law; criticisms of the OCC report’s analysis and conclusions; how the OCC and other financial regulators are expected to follow up on the OCC’s findings; how financial institutions can best defend themselves against allegations of debanking.

Related information:

https://www.occ.gov/news-issuances/news-releases/2026/nr-occ-2026-90.html

Federal Judge Rebuffs CFTC, Gemini on Bid to Vacate Settlement

Consider writing about:

The latest developments involving a $5 million settlement reached by the Gemini cryptocurrency platform in 2025; basis for a request by Gemini and the Commodity Futures Trading Commission to void the settlement; why a New York federal judge denied that request last week; what this case may illustrate regarding voluntary vs. involuntary consent to an agreement, shifting federal attitudes toward crypto, and possible courses of action when dealing with regulators.