Davis Polk’s Client Updates page aggregates a series of late-September and October 2025 analyses spanning sanctions, financial regulation, capital markets, and technology policy. Leading the list is a briefing on the U.S. government’s blocking sanctions against the two largest Russian oil producers, characterized as the first such action under Trump, amid stalled efforts to negotiate an end to the Ukraine war. Other policy developments include a proposal to codify safety-and-soundness and reputational risk expectations by the FDIC and OCC, as well as an SEC-focused piece examining Chairman Paul Atkins’ push to reframe shareholder proposals under Rule 14a-8 in Delaware.
Bank regulatory and enforcement topics feature prominently. FinCEN and the federal banking agencies issued new FAQs intended to streamline suspicious activity reporting obligations, while an SEC Enforcement Update tallies 52 actions against a combined 85 defendants and respondents between June and August 2025, excluding follow-on actions, bars and suspensions. With a potential federal shutdown looming, Davis Polk outlines practical considerations for public companies and transaction teams, complemented by a separate note on fresh SEC guidance designed to facilitate IPOs during a shutdown period.
On trade controls, a client update explains the Bureau of Industry and Security’s interim final “50% rule,” effective immediately, which extends U.S. export control restrictions associated with the Entity, MEU and SDN lists. The page also covers the latest in investment management, highlighting an extension of the compliance date for Form PF amendments and noting a recent enforcement action, as well as a monthly funds regulatory wrap-up.
Technology and state policy developments are part of the mix. A California-focused analysis reports that the governor signed the Transparency in Frontier Artificial Intelligence Act, described as the first U.S. law aimed at developers of frontier Artificial Intelligence models, with an effective date of January 1, 2026. Additional capital markets and supervisory insights round out the collection, including key takeaways from the FDIC and OCC proposals and topical guidance for navigating regulatory uncertainty.
