While ransomware attacks usually grab the headlines, business email compromise (BEC) attacks continue to cause massive financial losses for businesses. The FBI’s Internet Crime Complaint Center (IC3), reported BEC losses in...more
2/27/2023
/ Anti-Money Laundering ,
Banking Sector ,
BSA/AML ,
Business E-Mail Compromise (BEC) ,
Consumer Financial Protection Bureau (CFPB) ,
Corporate Counsel ,
Data Breach ,
Financial Crimes ,
Financial Institutions ,
Money Laundering ,
Popular ,
Uniform Commercial Code (UCC)
As described in DWT's October 2021 post, the Corporate Transparency Act ("CTA"), enacted as part of the Anti-Money Laundering Act of 2020, establishes beneficial ownership reporting requirements for a broad range of entities...more
With Real-Time Payments from The Clearing House rapidly gaining traction among banks and FedNow set to launch next July, one might believe that adoption of instant payments among network participants and users will be smooth...more
Key developments in the United States over the past several months have kicked the digital currency transformation discussion into high gear. After the President’s Working Group on Financial Markets’ November 2021 Report on...more
In July, we discussed the federal banking agencies' proposal to harmonize their respective risk management guidance. At the time, we highlighted three passages from the proposal that relate to the due diligence banking...more
Our team is pleased to announce an important publication on FinTech developments and regulation in the United States. Authored by Andrew Lorentz and Thomas Kost—and drawing on contributions from many DWT colleagues—the...more
Last week, the federal banking agencies—Federal Reserve Board (Board), Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC)—issued proposed interagency guidance ("Proposal") on...more
The Consumer Financial Protection Bureau (CFPB) has been very clear that fair lending and racial equity are top priorities for the agency under Acting Director Dave Uejio. Support of those priorities will be far-reaching. ...more
On February 14, 2019, DWT FinTech co-chair Andy Lorentz gave a presentation on lessons learned from recent BSA/AML enforcement actions–a continued area of emphasis in a de-regulatory climate–to the Innovative Payment Alliance...more
On Thursday, November 8, DWT FinTech team co-leader Andy Lorentz took part in the Commerce.Innovated Class 8 Demo Day in New York City. Andy led a discussion on legal developments in FinTech, with a focus on federal...more
On March 15, 2017, the Office of the Comptroller of the Currency issued a “Draft Supplement” to the Comptroller’s Licensing Manual, entitled “Evaluating Charter Applications from Financial Technology Companies” (Supplement)....more
Since Comptroller of the Currency Thomas J. Curry announced last December that the OCC will move forward to consider granting special purpose national bank charters to financial technology companies—under the OCC’s existing...more
On December 2, 2016, Comptroller of the Currency Thomas J. Curry announced that the OCC will move forward with considering granting federal charters—under the OCC’s existing authorities—to financial technology companies. ...more