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On May 16, 2018, FinCEN issued Administrative Ruling FIN-2018-R002, "Beneficial Ownership Requirements for Legal Entity Customers of Certain Financial Products and Services with Automatic Rollovers or Renewals," to provide a 90-day limited exceptive relief from the obligations of the Beneficial Ownership rule with respect to certain financial products and services that automatically rollover of renew (certificates of deposit or loan accounts). On May 22, FinCEN announced a correction to the last paragraph of the Administrative Ruling, where the rules applicability date was incorrectly given. The date has been corrected to May 11, 2018. The revised version of FIN-2018-A002 is available on FinCEN's website.

Editor's Note: The "exceptive relief" provided by FIN-2018-R002 extends only to certificates of deposit and loans that automatically rollover or renew. Loan renewals that are not automatic are not covered, and currently are subject to Beneficial Ownership requirements. They are covered, however, by Question 12 in FinCEN's April 3, 2018, Guidance FAQs (FIN-2018-G001).

OFAC has posted a notice that it has issued Ukraine-/Russia-related General License 15, which authorizes U.S. persons to engage in specified transactions related to winding down or maintaining business with GAZ Group and its subsidiaries until October 23, 2018. OFAC is also issuing Ukraine-/Russia-related General License 12C, which replaces and supersedes General License 12B in its entirety. General License 12C permits originating and intermediary U.S. financial institutions to process funds transfers that they would otherwise block to an account held by a blocked U.S. person at a U.S. financial institution. In addition, General License 12C clarifies that U.S. financial institutions can release such funds for authorized maintenance and wind-down purposes. OFAC is also publishing six new Frequently Asked Questions (FAQs) and revisions to existing FAQs about these general licenses.

The president has signed S.J. Res. 57, a joint resolution of disapproval under the Congressional Review Act (CRA) of the rule issued by the CFPB in the form of guidance concerning indirect automobile lender compliance with the ECOA and Regulation B. The March 21, 2013, guidance, in CFPB Bulletin 2013-02, has been voided by the CRA action, and the Bureau is now banned from reissuing a substantially similar rule unless specifically authorized to do so by law, according to a statement by Acting Bureau Director Mick Mulvaney.

Mulvaney also said that, following a recent Supreme Court decision "distinguishing between antidiscrimination statutes that refer to the consequences of actions and those that refer only to the intent of the actor, and in light of the fact that the Bureau is required by statute to enforce federal consumer financial laws consistently, the Bureau will be reexamining the requirements of the ECOA." The Bureau will also be reviewing other guidance documents it has issued with congressional staff and federal agency partners to identify those that must be submitted to Congress for review under the CRA.

The President has issued an Executive Order, "Prohibiting Certain Additional Transactions with Respect to Venezuela." All transactions related to, provision of financing for, and other dealings in the following by a United States person or within the United States are prohibited:

• the purchase of any debt owed to the Government of Venezuela, including accounts receivable;
• any debt owed to the Government of Venezuela that is pledged as collateral after the effective date [12:30 p.m. EDT on May 21, 2018] of the order, including accounts receivable; and
• the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela of any equity interest in any entity in which the Government of Venezuela has a 50 percent or greater ownership interest.

The Federal Emergency Management Agency has published a final rule in today's Federal Register announcing that it will suspend unincorporated areas of Mason County, Illinois, and the City of Harvey, Wells County, North Dakota, from the National Flood Insurance Program on June 6, 2018, for failure to comply with the floodplain management requirements if the program.

The NCUA Board has published [83 FR 23491] a notice of its May 24, 2018, 10:00–10:45 a.m. EDT, open meeting. On the agenda are discussions of two NCUA regulations: Involuntary Liquidation and Claims Procedures and Payday Alternative Loans.

The Federal Reserve Board and OCC have announced they are extending the comment period on their previously announced proposal to modify the enhanced supplementary leverage ratio standards for U.S. top-tier bank holding companies identified as global systemically important bank holding companies, or GSIBs, and certain of their insured depository institution subsidiaries. The proposal also included conforming modifications to the Board’s total-loss absorbing capacity and long-term debt rules. The end of the comment period has been changed from May 21 to June 25, 2018.

OFAC announced on Friday it has designated Diosdado Cabello Rondón (Cabello), for being a current or former official of the Government of Venezuela. OFAC also designated three other individuals (one with addresses in the U.S.) for being current or former officials, or for acting for or on behalf of designated individuals as key figures in the Cabello corruption network, and three companies and 14 properties in Florida and New York owned by one of those individuals. Identifying information is available in our May 18 OFAC Update.

Treasury's Office of Foreign Assets Control has designated Hizballah financier Mohammad Ibrahim Bazzi and Hizballah’s representative to Iran Abdallah Safi-Al-Din as Specially Designated Global Terrorists (SDGTs) pursuant to Executive Order 13224, which targets terrorists and those providing support to terrorists or acts of terrorism. Also designated on Thursday as SDGTs are five companies located in Europe, West Africa, and the Middle East for being owned or controlled by Mohammad Bazzi and another SDGT. For identity information on the individuals and companies targeted by OFAC's actions, see our OFAC Update.

The Bureau has posted an article announcing the availability of a new list that identifies more ways to access credit scores for free.