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U.S. Firms Continue to Face Liability for Terrorist Attacks under the Antiterrorism Act

Last year, a group of U.S. military veterans and the relatives of troops killed in Iraq filed a lawsuit against several large international pharmaceuticals, accusing them of aiding and abetting terrorism by selling products...more

Compliance with Initial New York DFS Cybersecurity Rules Now Mandatory

As of August 28, 2017, insurance companies, banks, and other financial services companies regulated by the New York Department of Financial Services (“DFS”) must comply with an initial wave of new cybersecurity requirements...more

FinCEN Issues New Geographic Targeting Order for Shell Companies Purchasing High-End Residential Real Estate

In its latest effort to combat money laundering within the real estate sector, the Financial Crimes Enforcement Network (“FinCEN”) has issued a new Geographic Targeting Order (“GTO”) broadening its scrutiny of shell companies...more

The Supreme Court’s Broad Interpretation of the Bank Fraud Statute May Provide a Potent Tool in Combatting Cybercrime

The Supreme Court in Shaw v. United States recently held that the federal bank fraud statute does not require that defendants cause, or intend to cause, an actual financial loss to the financial institutions they seek to...more

D.C. Circuit Brings CFPB under Presidential Control

On October 11, 2016, the United States Court of Appeals for the D.C. Circuit issued its long-awaited opinion in PHH Corp. v. Consumer Financial Protection Bureau, in which the Court held that the structure of the Consumer...more

CFPB Proposed Rules Address Payday Loans and Impose New Customer Diligence Requirements

The Consumer Financial Protection Bureau (“CFPB”) last week announced long-awaited proposed rules governing payday loans and other high-cost credit products, including that lenders must take steps to ensure prospective...more

FinCEN Issues Final Rules for Customer Due Diligence Requirements

On May 11, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued the final version of its long-awaited “Customer Due Diligence Rules” under the Bank Secrecy Act. The final rules impose a new requirement on...more

UK Financial Conduct Authority Issues Final Rules Concerning Whistleblowers

On October 6, 2015, the UK Financial Conduct Authority (“FCA”) issued final rules formalizing whistleblower procedures to be implemented by certain banks, building societies, credit unions, investment firms, and insurance and...more

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