Foreign Military Sales restrictions
Foreign Military Sales restrictions are an underappreciated compliance pressure point for Financial & Capital Markets firms, particularly those financing defense-adjacent transactions, underwriting sovereign debt for restricted counterparties, or providing correspondent banking to entities in the U.S. Department of State's FMS review scope. The U.S. Department of the Treasury's Office of Foreign Assets Control and the U.S. Department of State's Directorate of Defense Trade Controls both assert authority here, and their jurisdictions overlap in ways that create real exposure for capital markets desks that assume FMS is a defense-sector problem. Cresthaven is actively monitoring this intersection for regulatory actions, guidance updates, and enforcement patterns as they emerge.
Watch
- DDTC guidance on financial intermediaries facilitating FMS-adjacent transactions
- OFAC secondary sanctions designations affecting sovereign debt underwriting eligibility
- Congressional holds on FMS approvals that could trigger counterparty review obligations
- State Department FMS eligibility list changes touching APAC sovereign borrowers
Recent material activity in Financial & Capital Markets
A selection of recent published briefs; this is not a complete archive.
CFTC obtains federal court orders requiring Alexandre and EminiFX to pay over $288 million for commodity pool Ponzi scheme
The CFTC announced on October 19, 2026 that the U.S. District Court for the Southern District of New York entered orders against Eddy Alexandre and EminiFX Inc. for operating a commodity pool Ponzi scheme. The orders req…
Read a full sample brief →CIRO schedules December 8 settlement hearing for registered representative Patrick H. Watson
On October 19, 2026, CIRO announced that a settlement hearing has been scheduled for Patrick H. Watson. The notice alleges Watson failed to act as a gatekeeper to the capital markets. Canaccord Genuity Corporation is ide…
Read a full sample brief →CIRO opens active enforcement proceeding against Patrick H. Watson on gatekeeper obligations
CIRO has commenced an enforcement proceeding against Patrick H. Watson, with gatekeeper obligation failures as the central allegation. The source does not specify the conduct alleged, Watson's registration category, or t…
Read a full sample brief →ASIC cancels MWL Financial Services credit licence following CSLR compensation payment of $90,031
ASIC cancelled the Australian credit licence of MWL Financial Services Pty Ltd (In Liquidation) on 12 October 2026. The cancellation was mandatory and non-discretionary, triggered by a $90,031.34 CSLR payment made on 16 …
Read a full sample brief →RBI sanctions amalgamation of Emirates NBD Bank Indian branches into RBL Bank, effective December 1, 2026
The Reserve Bank of India has sanctioned the amalgamation of the Indian branches of Emirates NBD Bank P.J.S.C. with RBL Bank Limited. All Indian branches of Emirates NBD Bank will operate as branches of RBL Bank from Dec…
Read a full sample brief →SFC endorses HKEX proposal to shift Hong Kong equities settlement from T+2 to T+1 by September 2028
The SFC issued a statement on October 16, 2026 welcoming HKEX's Consultation Conclusions Paper on accelerated settlement for Hong Kong's cash equity market. HKEX has revised its implementation timeline to the second half…
Read a full sample brief →Brazil CVM consolidates securitization company regulation under Resolution 60, revoking four prior instructions
Brazil's Comissão de Valores Mobiliários (CVM) issued Resolution 60 on December 23, 2021, consolidating the rules governing credit-rights securitization companies registered with the CVM. The resolution revoked four prio…
Read a full sample brief →Federal Reserve terminates three enforcement actions against Gardner Bancshares and Small Business Bank
The Federal Reserve Board terminated three enforcement actions against Gardner Bancshares, Inc. and Small Business Bank, both of Lenexa, Kansas, effective October 13, 2026. The terminated actions comprise two cease and d…
Read a full sample brief →LTSE files immediately effective rule change aligning clearly erroneous execution review with SEC-approved overnight trading price bands
On October 8, 2026, Long-Term Stock Exchange, Inc. filed a proposed rule change with the SEC, effective upon filing, to amend its clearly erroneous execution rule. The amendment aligns the rule with the SEC's August 5, 2…
Read a full sample brief →Nasdaq ISE proposes to eliminate cross-market risk controls shared with affiliate Nasdaq GEMX
Nasdaq ISE, LLC filed a proposed rule change on October 1, 2026, granted immediate effectiveness by the SEC, to amend its Market-Wide Speed Bump and Kill Switch. The proposal removes existing cross-market functionality t…
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