December 29, 2019
It is critical that limited operation companies does not come to include those which may be subject to US trade sanctions with stipulations around financial services. Further, any or all relevant and eligible parties must clearly disclose to retail and institutional investors whether that company or security is currently subject to trade sanctions. If compliance information is provided by said company that may present a regulatory issue, whether in terms of a lapse in enforcement of trade sanctions or otherwise, regulatory authorities must quickly and expediently provide definitive answers to public inquiries posed to the body. Issues raised may not be deferred indefinitely, especially as they may relate to ongoing matters such as those of presidential impeachment before US Congress. Given the fluid nature of US foreign policy and the evolving nature of global current events which drives it, the SEC must work swiftly in tandem with the Office of Financial Asset Control (OFAC) as well as the American public to address any potential concerns as they arise.
To that end, having certain securities be the exclusive domain of experts may also present a potential issue which could compound systemic risks to the global markets and global economy. It is critical that all information for all public companies and securities stay just that, public. Delegating specific knowledge of certain corporate bodies to industry experts also introduces an unsustainable risk asymmetry to society at large. In keeping with the spirit of our American way of life and the open, transparent, connected spirit of OTC securities, publicly traded companies must remain public until designated otherwise in a manner that complies with US trade policy. If not, foreign adversaries may uncover means to navigate the emerging regulatory landscape in ways that evade the intent of trade sanctions imposed against them.