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Federal Court Holds Financial Institution Liable for Business Email Compromise Loss

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

FinCEN Beneficial Ownership Information Access Proposal Raises Many Questions

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

Thoughts on the Wave of Payment Processor Mega-Mergers

There has been an unprecedented wave of consolidation in the U.S. payment processing industry this year, with two major core processors acquiring the two largest merchant acquirers, and two of the largest remaining payment...more

Federal Reserve Enters Consent Order to Sanction Deceptive Practice Involving Credit Card Product

The Board of Governors of the Federal Reserve System (Federal Reserve) recently exercised its authority to enforce laws prohibiting unfair or deceptive acts or practices committed by a financial institution under the Federal...more

Update: NACHA Adopts Same-Day ACH Rule

Update: The Federal Reserve received forty comments in response to its request. A majority of the commenters supported both mandatory participation by RDFIs and the same-day fee payable by ODFIs to RDFIs. Many commenters...more

CFPB Inserts Consumer Protection Issues into Faster Payment System Developments

The Consumer Financial Protection Bureau recently issued a series of Consumer Protection Principles to be considered as new, faster payment systems are being developed. The Rapidly Changing Regulatory Landscape for Faster...more

Plus ça change…NYDFS releases final BitLicense regulations

The New York State Department of Financial Services (NYDFS) released final BitLicense regulations on June 3, 2015, almost eleven months after the initial BitLicense proposal was issued. The initial proposal went through two...more

NACHA Adopts Same-Day ACH Rule

On May 19, NACHA adopted a rule enabling the same-day processing and settlement of most types of ACH payments (same-day rule). In 2012, NACHA had proposed an Expedited Processing and Settlement (EPS) rule providing for a...more

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