Pia Naib

Pia Naib

Latham & Watkins LLP

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NYSDFS Revises Cybersecurity Rules to Accommodate Industry Concerns

The revised regulations eliminate many of the categorical requirements in the original proposal and instead adopt a more risk-based approach. On December 28, 2016, the New York State Department of Financial Services...more

1/6/2017 - Amended Rules Cybersecurity NYDFS Risk Assessment State Data Breach Notification Statutes

Financial Institutions Await Response to Concerns Over NYSDFS’ Proposed Cybersecurity Rules

Comments submitted on the proposed regulations criticize the lack of a risk-based approach, overbroad definitions, potential extraterritorial implications, an excessive breach notification threshold and a daunting annual...more

12/23/2016 - Chief Information Officers (CIO) Cybersecurity Financial Institutions NYDFS Proposed Regulation

OCC to Make Available Special Purpose National Bank Charters to Fintech Companies

While many fintech companies will welcome the regulatory approach, banks and state regulators have some concerns. In a long-awaited move aimed at establishing some clarity around the regulatory framework for companies...more

12/20/2016 - Financial Services Industry FinTech OCC Popular Regulatory Standards Special Purpose National Bank Charter

Bitcoin Again Held to Be “Funds” for Federal Money Transmitting Purposes

Murgio decision reflects a growing judicial consensus around the application of money transmitting laws to Bitcoin exchangers. On September 19, 2016, U.S. District Judge Alison J. Nathan of the Southern District of New...more

9/26/2016 - Bitcoin Indictments Money Transmitter Popular Virtual Currency

Virtual Currencies: Court Rules that Selling Bitcoin Is Not Money Transmitting and Selling Bitcoin to Criminals Is Not a Crime

The ruling is an outlier driven by its unique facts and is unlikely to change the general regulatory landscape for Bitcoin businesses. In State of Florida v. Espinoza, a trial court in Miami recently dismissed all...more

9/1/2016 - Bitcoin Criminal Prosecution Dismissals Money Transmitter Virtual Currency

New York State Department of Financial Services Releases Final Regulations to Enhance Anti-Money Laundering and Sanctions...

Final regulations impose certification requirements on a financial institution’s Board of Directors or Senior Officer(s) relating to BSA/AML and OFAC compliance. The New York State Register today published the final...more

7/21/2016 - Anti-Money Laundering Bank Secrecy Act Board of Directors Certification Requirements Compliance Corporate Executives Final Rules Financial Institutions NYDFS OFAC Suspicious Activity Reports (SARs) Training Requirements

New York State Department of Financial Services Proposes Regulations to Enhance Anti-Money Laundering and Sanctions Compliance for...

Proposed regulations impose new certification requirements that could result in personal liability for compliance officers of financial institutions. On December 1, 2015, the New York State Department of Financial...more

12/23/2015 - Anti-Money Laundering BSA/AML Financial Institutions NYDFS OFAC Sanctions

Federal Reserve Board Grants One-year Extension on Volcker Rule Conformance for Certain Covered Funds

The Federal Reserve today extended the Volcker Rule conformance period for legacy covered funds from July 21, 2015 to July 21, 2016, and also granted a further one year extension until July 21, 2017. At 3 pm today...more

12/19/2014 - Banks Covered Entities Dodd-Frank Federal Reserve Time Extensions Volcker Rule

Virtual Currencies: New York State Department of Financial Services Discusses Proposed Regulations

As the proposed BitLicense takes shape, New York regulators are engaging in discussions with industry players. On October 14, 2014 Benjamin N. Cardozo School of Law organized a panel discussion as part of its Tech...more

10/23/2014 - Bitcoin Department of Financial Services Virtual Currency

Virtual Currencies: New York State Department of Financial Services Releases Proposed Regulations

As the first of their kind, the proposed regulations may add legitimacy to virtual currencies, but the new regulatory regime could stifle innovation and development. On July 23, 2014, the New York State Department of...more

8/1/2014 - Banking Sector Bitcoin Cryptocurrency Department of Financial Services Federal Reserve Innovation Licensing Rules Proposed Regulation Public Comment Virtual Currency

Volcker Rule: An Initial Look at Significant Changes

On December 10, 2013 the US federal banking agencies, along with the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) (collectively, the Agencies), adopted the ...more

12/24/2013 - Banks CFTC Dodd-Frank SEC Volcker Rule

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