On July 1, 2024, the Supreme Court issued its opinion in Corner Post, Inc. v Board of Governors of the Federal Reserve System in which the Court determined when a Section 702 claim under the Administrative Procedure Act (APA)...more
7/5/2024
/ Administrative Procedure Act ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Corner Post Inc v Board of Governors of the Federal Reserve System ,
Debit Cards ,
Federal Reserve ,
Final Rules ,
Financial Crimes ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
FinCEN ,
Interchange Fees ,
Regulation II ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Statute of Limitations
The report examines the vulnerabilities in DeFi, including potential gaps in the United States’ Bank Secrecy Act/anti-money laundering regulatory, supervisory, and enforcement regimes for DeFi. We first discuss how Treasury...more
6/22/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Enforcement Actions ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Risk Mitigation ,
State Regulators ,
U.S. Treasury
The New York State Department of Financial Services (NYDFS) has come out strongly against an Office of the Comptroller of the Currency (OCC) proposal to grant national bank charters to financial technology (fintech)...more
1/30/2017
/ American Bankers Association ,
Anti-Money Laundering ,
Banking Sector ,
Banks ,
Capital Requirements ,
Community Reinvestment Act ,
Consumer Financial Protection Bureau (CFPB) ,
Fair Lending ,
FDIC ,
Federal Reserve ,
FinTech ,
Fintech Charter ,
National Bank Act ,
National Bank Charters ,
NYDFS ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Oversight ,
Technology ,
Terrorism Funding
The U.S. Department of the Treasury and four U.S. federal banking regulators have issued the "Joint Fact Sheet on Foreign Correspondent Banking" in an effort to clarify enforcement priorities regarding Anti-Money Laundering...more
9/2/2016
/ AML/CFT ,
Anti-Money Laundering ,
Banking Sector ,
Banks ,
BSA/AML ,
Depository Institutions ,
Due Diligence ,
Foreign Correspondent Banking ,
Foreign Financial Institutions (FFI) ,
International Monetary Fund ,
U.S. Treasury
The New York Department of Financial Services (DFS) has finalized a new regulation setting rigorous standards for monitoring and filtering programs to monitor transactions for potential anti-money laundering (AML) and Bank...more
7/6/2016
/ Anti-Money Laundering ,
Banking Sector ,
BSA/AML ,
Certificates of Compliance ,
Disclosure Requirements ,
Financial Institutions ,
Foreign Banks ,
Money Transmitter ,
NYDFS ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Senior Managers ,
Transaction Monitoring
The Federal Deposit Insurance Corporation's (FDIC) publication of an article highlighting the risks for banks that partner with marketplace lenders further underscores the focus of federal regulators on marketplace lending....more
The New York Department of Financial Services (DFS) has proposed new regulations setting forth minimum standards for anti-money laundering (AML) transaction monitoring and filtering systems. The regulations, proposed December...more
For the second time in two years, Benjamin Lawsky, the Superintendent of the New York State Department of Financial Services (DFS), has settled another matter with Standard Chartered Bank for alleged “anti-money laundering...more
Benjamin M. Lawsky, who heads the New York State Department of Financial Services (DFS), indicated that his agency is seriously considering more aggressive investigation and pursuit of individuals whose malfeasance has led...more
The Financial Crimes Enforcement Network (FinCEN) has issued formal guidance to clarify the anti-money laundering obligations of administrators and exchangers of convertible virtual currency.
“Virtual” currency, unlike...more
HSBC Holdings, London, and two of its U.S. subsidiaries have been ordered to pay a record $1.92 billion in fines and penalties for anti-money laundering (AML) and Office of Foreign Assets Control (OFAC) violations....more